Lacking the ability to issue formal no-action relief from strict compliance with the variation margin rules for uncleared swaps coming into effect on March 1, the Board of Governors of the Federal Reserve System, the Office of Comptroller of the Currency (OCC) and the European Supervisory Authorities (ESA) have each issued statements suggesting that they will exercise some forbearance in enforcing the margin rules after March 1 if a swap dealer subject to their respective regulations is diligently pursuing compliance on that date. The communications from the Federal Reserve Board and the OCC follow the lead of the no-action relief issued by the Commodity Futures Trading Commission on February 13 by pointing to September 1 as the latest date for full compliance. The ESA communication is stricter in tone and does not identify a specific period in which enforcement will be relaxed. (There are no equivalent statements from the other US prudential regulators because they do not regulate any swap dealers and therefore do not have this issue.)

The Federal Reserve Board statement is available here. The OCC statement is available here.

The ESA statement is available here.