Today is the first compliance date for our rules requiring margin for uncleared swaps, which generally covers transactions between swap dealers. CFTC staff has been made aware that some dealers have not been able to complete all documentation required to comply with the custodial arrangements required by CFTC rules, due to the limited number of providers of such services and the volume of custodial agreements that market participants are requesting. While it is staff's understanding that this situation has improved in the last few days, and that the largest dealers may no longer face significant issues, staff has heard that smaller firms or foreign firms may not have been able to complete all arrangements or test these new facilities.
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