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OCC Bulletin 2017-12
February 23, 2017
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Chief Executive Officers and Compliance Officers of National Banks and Federal Savings Associations, Federal Branches and Agencies, Department and Division Heads, All Examining Personnel, and Other Interested Parties
The Office of the Comptroller of the Currency (OCC) is providing guidance regarding initial examinations of OCC-supervised institutions for compliance with certain provisions of the interagency rule (“final rule”) establishing initial and variation margin requirements for non-cleared swaps and non-cleared security-based swaps (collectively, “non-cleared swaps”). Specifically, this guidance addresses the OCC’s expectations for compliance by national bank swap dealers with minimum variation margin requirements that will become applicable on March 1, 2017.
This guidance has no impact on community banks with $10 billion or less in total assets.
On December 3, 2015, the OCC issued Bulletin 2015-49, “Margin Requirements for Non-Cleared Swaps and Non-Cleared Security-Based Swaps.” This bulletin made the final rule available on the OCC website.
The effective date for the final rule was April 1, 2016. However, the phase-in of the minimum margin requirements did not begin until September 1, 2016. Under the final rule, the largest swap counterparties (those with more than $3 trillion in outstanding swap activity) were required to implement both the initial and variation margin requirements for non-cleared swap trades between those largest swap counterparties by September 1, 2016. On March 1, 2017, the phase-in schedule will begin to encompass all covered swap entities, regardless of the volume of outstanding swap activity, for the exchange of variation margin for all transactions with other swap entities and financial end-user counterparties.
Grace E. Dailey
Senior Deputy Comptroller and Chief National Bank Examiner
Amy S. Friend
Senior Deputy Comptroller and Chief Counsel