Participants discussed the proposed margin rule for uncleared swaps, in particular margin requirements for swaps between affiliates.

Participants discussed the proposed margin rule  for uncleared swaps. The particular issues were: implementation timeline (VM "big bang"), margin requirement between affiliates, international harmonization (substituted compliance regime) and treatment of collateral (segregation and rehypothecation limitations).

Participants discussed practical issues with implementation of proposed rule as well as need for international harmonization.

Staff of the CFTC and the Federal Reserve met with MFA to discuss (i) current market practices for hedge funds in posting margin and (ii) the definition of control, as it relates to the proposed margin rule.

Participants discussed various issues regarding margin requirements for uncleared swaps (see attachment).

The WGCEF discussed its February 10, 2014 comment letter no. 59693, including:  Calendar Month Average pricing; the “Economically Appropriate” criterion of the bona fide hedging definition; and requested clarification of the aggregation provisions in proposed regulation 150.3(i) as it relates to the Form 204 instructions for excluding certain source commodities, products, or byproducts.

Commissioner Bowen met with Morgan Stanley to discuss the position limits regulation and its implementation.

Participants talked about the proposed

Requested information regarding whether AGA should address certain topics in its comment letter, including whether the interpretation constitutes a safe harbor and a request for an extension from the 2015 Form TO filing requriement

Participants discussed proposed amendment to Regulation 1.35, Records of Commodity Interest and Related Cash or Forward Transactions.