A notice of proposed rulemaking (NPR) from joint US regulators including the Federal Reserve and the Federal Deposit Insurance Corporation has proposed new margin requirements for swap dealers and end-users, including airlines, to set aside money to reduce risk in certain trades. However similar rules proposed by the Commodity Futures Trading Commission suggested end-users will be exempt from such margin requirements. The Dodd-Frank Act requires agencies including the CFTC, Securities and Exchange Commission and the Fed to establish margin requirements as a way of limiting risk in the global swaps market. However airlines have argued that they use derivatives genuinely

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