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The CFTC unanimously adopted final rules amending
uncleared margin requirements to, among other things: (i) amend the
period for the calculation of the average aggregate notional
amount for purposes of scoping firms subject to initial
margin requirements, and (ii) modify the application of minimum
transfer amounts ( MTAs ) with respect to separately
managed accounts.
Each rule will go into effect 30 days after its publication in
the Federal Register.
Amendments to the AANA Calculation
As previously covered, the final rule amends the
definition of material swap exposure ( MSE )