On October 16, the Commodity Futures Trading Commission (CFTC) unanimously extended the compliance schedule for initial margin requirements for uncleared swaps for entities with average aggregate notional amounts in material swaps exposure of $8 – $50 billion until September 1, 2021. Entities with more than $50 billion of such exposure are still subject to the September 1, 2020 compliance date.

In addition, the CFTC also voted to exclude the European Stability Mechanism from the definition of “financial end user” for purposes of margin requirements for swap dealers and major swap participants. This result is consistent with existing no-action relief.

The CFTC press release, with lists to the relevant Federal Register releases, is available here.