The OCC, FRB, FDIC, FCA, and FHFA have issued a proposal to amend the minimum margin requirements for registered swap dealers, major swap participants, security-based swap dealers, and major security-based swap participants for which one of the agencies is the prudential regulator (Swap Margin Rule).  Specifically, the proposed rule would amend the definition of "Eligible Master Netting Agreement" (EMNA) in the Swap Margin Rule to make the EMNA definition consistent with the definition of "Qualifying Master Netting Agreement" in the Federal banking agencies’ regulatory capital and liquidity rules, which were recently amended by rules adopted by the OCC, FRB, and FDIC (QFC Rules).  This consistency will ensure that netting agreements of firms subject to the Swap Margin Rule are not excluded from the EMNA definition based solely on their compliance with the recently-adopted QFC Rules.  The proposed rule would also clarify that any grandfathered non-cleared swap that is entered into before the applicable compliance date of the Swap Margin Rule and that is thus not subject to its margin requirements would not become subject to the Swap Margin Rule if the grandfathered non-cleared swap is amended solely to comply with the QFC Rules.