Statement of Support by Commissioner Brian D. Quintenz Regarding Final Rule on Definition of Material Swap Exposure and the Method for Calculating Initial Margin
December 08, 2020
he philosophy behind such a framework is that firms with small levels of swaps can have outsized impacts on the financial system. Further, the fact that we, as an agency and as international regulators, continue to embrace a metric as useless, biased, and arbitrary as notional value is something I have long opposed, and I have never, not once, heard an acceptable or even rationale defense for doing so.
 Definition of material swap exposure under reg. 23.151(a).
 CFTC Letter 19-29.