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On 07/26/2023, the Commodity Futures Trading Commission (Commission) approved a notice of proposed rulemaking (NPRM) that proposed amendments to the regulations governing uncleared swaps for swap dealers and major swap participants for which there is not a prudential regulator. These proposed amendments would revise the definition of margin affiliate to provide that certain collective investment vehicles that receive a portion or all of their initial equity investment from a sponsoring entity would be deemed not to have any margin affiliates for the purposes of calculating certain thresholds that trigger the requirements to exchange initial margin (IM), effectively relieving swap dealers and major swap participants from posting and collecting IM with certain eligible seeded funds for a limited, three year period. The amendments would also include a proposal to eliminate a provision disqualifying the securities issued by certain pooled investment funds that transfer their assets through securities lending, securities borrowing, repurchase agreements, reverse repurchase agreements, and similar arrangements from being used as eligible IM collateral. In addition, the amendments would codify a staff interpretive letter regarding margin. Finally, the Commission included a proposed technical amendment to the haircut schedule set forth in Regulation 23.156(a)(3)(i)(B) to add a footnote that was inadvertently omitted when the rule was originally promulgated.