Stroock Special Bulletin
"CFTC’s DSIO Issues Time-Limited No-Action Letter Relating to Variation Margin Requirements"
Will Not Recommend Enforcement Action Against Swap Dealers for Failure to Comply with Variation Margin Requirements for Swaps Subject to March 1, 2017 Compliance Date
Yesterday the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (“DSIO”) issued a time-limited no-action letter stating that from March 1, 2017, to September 1, 2017, DSIO will not recommend an enforcement action against a swap dealer (“SD”) for failure to comply with the variation margin (“VM”) requirements for swaps that are subject to a March 1, 2017 compliance date.
This Stroock Special Bulletin provides a brief overview of the no-action letter.