Key takeaways

• The CFTC has adopted final rules addressing the cross-border application of its margin rules for non-cleared swaps entered into by swap dealers and major swap participants for which no U.S. federal banking agency is a prudential regulator.
• The final rules are generally consistent, in substance, with the U.S. prudential regulators’ cross-border application of their own joint final margin rules for swap dealers and major swap participants whose prudential regulator is one of the U.S. federal banking agencies.
• The final rules will become effective on August 1, 2016, and the applicable compliance dates are set forth in the CFTC's margin rules.