Meeting Date:
Friday, October 9, 2015
CFTC Staff:
Jonathan Marcus, Paul Schlichting, Carlene Kim, Francis Kuo, Lihong McPhail, Stephen Kane, Rafael Martinez
Organization(s):
Credit Suisse (CS)
External Attendees:
Gautam Gujral (CS), Maggie M. Gage (CS), Edward Tsai (CS)
Additional Information:
Visitors presented a list of concerns regarding the rule on margin requirements on uncleared swaps. Discussed were the cost of applying the requirements to inter-affiliate swaps, concerns with custody arrangements, application to novation of legacy swaps, internal model approval, theoretical calculation of margin for exempt counterparties and timing of posting of collateral.