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The Swap Margin Rule takes effect under a phased compliance schedule stretching from 2016 through 2020, and the dealers covered by the rule continue to hold swaps in their portfolios that were entered into before the effective dates of the rule. These swaps are grandfathered from the Swap Margin Rule’s requirements until they expire according to their terms. The OCC, FRB, FDIC, FCA, and FHFA plan to issue a proposed rule that would allow these grandfathered swaps to be amended to (1) replace existing interest rate provisions based on certain benchmark interbank offered rates and similar interest rates that may be discontinued in the future and (2) permit certain amendments, including immaterial amendments to non-economic terms and amendments that reduce operational or counterparty risk, such as notional reductions, partial terminations, and compression exercises.  The proposed rule would also repeal the current Swap Margin Rule’s section imposing special requirements for the exchange of initial margin for inter-affiliate swaps and clarify existing trade documentation requirements.