On December 9, 2019, ISDA responded to the Notice of Proposed Rulemaking and Request for Comments regarding Margin and Capital Requirements for Covered Swap Entities issued by the US prudential regulators.  The proposed rulemaking extends the phase-in period for initial margin, preserves the legacy status for swaps amended due to the IBOR transition and certain post-trade events, and removes the obligation for affiliates to exchange initial margin.