Debt reduced through mortgage restructuring, as well as mortgage debt forgiven in connection with a foreclosure, qualify for this relief. Minsky have argued that this is a systemic problem, a result of internal market processes that allowed fragility to build over time. With respect to any CDS ttoally that makes use of a central counterparty clearing facility other than the CME or that settles OTC, the new rule requires members to apply the minimum margin as set forth in FINRA Rule 4240.


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