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March 30, 2015

By: Marvin J. Goldstein, Scott Le Bouef, Christopher Guhin

On March 18, 2015, the Basel Committee on Banking Supervision and the International Organization of Securities Commissions announced changes to the implementation schedule set forth in the international framework “Margin requirements for non-centrally cleared derivatives” (the “International Framework”), which was issued on September 2, 2013.  This Stroock Special Bulletin describes these changes and provides a brief summary of other key terms of the International Framework and the current proposals from the CFTC and the Prudential Regulators with respect to minimum initial and variation margin requirements for uncleared swaps and security-based swaps.