On September 26, 2012, several regulators, including the Federal Reserve Board and the FDIC, reopened the comment period for proposed rules under the Dodd-Frank Act that would require most banks and financial institutions that are registered swap dealers, security-based swap dealers, major swap participants or major security-based swap participants to collect margin collateral from their uncleared swap counterparties (for more information on the proposed rules, see Legal Update, Regulators Propose Conflicting Rules on Uncleared Swap Margin Requirements).

The regulators reopened the comment period until November 26, 2012 to give interested parties an opportunity to comment on the rules in light of a consultative paper on uncleared swap margin collateral matters that was jointly published by the Basel Committee on Banking Supervision (BCBS) and IOSCO on July 6, 2012.

To learn more about swap margin collateral requirements under Dodd-Frank, see Practice Note, The Dodd-Frank Act: Derivatives Margin Collateral Rules.