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Better Markets Comment Letter on Margin and Capital Requirements for Covered Swap Entities

Better Markets filed a comment letter on a proposed rulemaking to eliminate initial margin requirements on interaffiliate derivatives transactions between derivatives dealing banks and their affiliates.  The proposal was issued by the Federal Reserve, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Farm Credit Administration, and the Federal Housing Finance Agency. 

In its letter to the agencies, Better Markets explains that the proposal would do each of the following:  

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