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In October 2014, the Commission proposed marginrules for uncleared swaps of covered swap entities and sought comment on three alternative approaches to the application of its margin rules in the context of cross-border transactions.  In July 2015, after reviewing public comments on the three alternative approaches, the Commission issued for public comments its proposal on the cross-border application of its margin rules; the comment period ended September 14, 2015. In January 2016, the Commission published a final rule that established initial and variation margin requirements for swap dealers (SDs) and major swap participants (MSPs) but would not require SDs and MSPs to collect margin from non-financial end users.  The Commission also published and invited comment on an interim final rule that would exempt certain uncleared swaps with certain counterparties from these margin requirements.