On May 24, 2016, the Commodity Futures Trading Commission (CTFC) issued a rule implementing a cross-border approach to its margin requirements for uncleared swaps. The CFTC's margin rule applies to CFTC-registered swap dealers and major swap participants for which there is no prudential regulator (collectively, covered swap entities), but these rules are closely aligned with the cross-border margin requirements already adopted by the prudential regulators. The final rule generally requires covered swap entities to comply with the CFTC's margin requirements for all uncleared swaps in cross-border transactions, with a limited exclusion for certain non-US covered swap entities...View full memo, Final Cross-Border Margin Rule Issued