The Division of Clearing and Risk (“DCR”) recently received several inquiries regarding the implementation of amendments to Regulation 39.13(g)(8)(ii) that the Commission adopted on January 27, 2020 with a compliance date of January 27, 2021.

DCR DSIO Issue Supplemental Advisory Grant of No-Action Relief from 1.56 and 39.13(g)(8)(iii)

No-action relief granted to a swap dealer concerning the calculation of initial margin under Commission regulation 23.154.

Staff Time-Limited No-Action Position Regarding Application of Minimum Transfer Amount under the Uncleared Margin Rules

Advisory to FCMs and time-limited no-action relief to DCOs with respect to the treatment of separate accounts by FCMs.

Advisory clarifying that no documentation concerning the collection, posting and custody of initial margin is required to be completed until the initial margin threshold amount of $50 million has been exceeded.

No-action relief granted to swap dealers from the uncleared swap margin requirements under Part 23 of the Commission's regulations with respect to certain amendments to legacy swaps.