Swaps and Hedges

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February 9, 2017
"Variation margin (VM) rules," which apply to U.S. swap dealers, are proposed to go into effect on March 1 in the U.S. To find out more about the protocols and possible exceptions to them, read our client alert.
Client Alert
April 9, 2013
As noted in our March 28, 2013 Client Alert, on March 15, 2013 the federal Commodity Futures Trading Commission (CFTC) issued an advisory which stated that all swap participants needed to obtain a Legal Entity Identifier number (also known as an LEI or CICI) prior to April 10, 2013. While the language of the CFTC’s advisory was unambiguous, it conflicted with a prior CFTC regulation which provided participants in existing swaps until October 7, 2013 to obtain a CICI (although anyone entering into a new swap on or after April 10 must have a CICI when entering into the new swap). Although some CFTC staff have reportedly orally acknowledged the October 7 date is correct, the CFTC has not yet officially clarified the advisory.
Client Alert
March 28, 2013

As part of the reporting regime under the Dodd-Frank Wall Street Reform and Consumer Protection Act, all parties to swap agreements (Swap Participants), including municipal issuers, need to have Legal Entity Identifier numbers (also known as LEIs or CICIs) that are used when dealers report swaps. Note this requirement even applies with respect to certain swaps that already have been terminated to the extent they were in effect on or after April 25, 2011. Read this client alert for more information about the need to apply for or certify LEIs.

Client Alert
March 15, 2013

In January 2013 the portions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (DFA) regulating swaps began to be phased in, including provisions regulating swaps entered into by state and local governments. Swap dealers have begun contacting their governmental and other swap counterparties requesting that they execute various documents in response to DFA. The following is a brief summary of the DFA provisions which directly affect state and local governments’ swaps, including new swaps, existing swaps or even, in some cases, terminated swaps.

Client Alert
December 3, 2012