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CFTC Staff Letter No. 26-03
Letter Type: Interpretative
Division: DCR, MPD
Regulation Parts: 2(h), 2(h)(1), 2(h)(1)(A), 4s(e), 23.150 - 23.161, 50.2, 50.4, 140.99
Tags: Clearing, Clearing Requirement, Margin, Legacy Swaps
Issuance Date: 01/30/2026
Description: Joint MPD and DCR interpretative letter addressing the effect of a merger conducted as part of Morgan Stanley’s internal reorganization on the status of certain legacy swaps. Based on the facts and circumstances of the merger as described in the letter, the divisions concluded the swaps at issue retain their legacy swap status under the Commission’s uncleared swap margin and swap clearing requirements.
See also: Request Letter
Requester(s): MORGSTAN