On March 18, 2009, the Financial Industry Regulatory Authority (FINRA) announced its proposal to the Securities and Exchange Commission for a pilot program to impose margin rules for credit default swaps transactions executed by a FINRA-registered broker-dealer and cleared by the Chicago Mercantile Exchange (CME) or other central counterparty platforms.  The new rule would apply to transactions executed by a member, regardless of the type of account in which the transaction is booked, and include transactions in which the member cleared offsetting matching hedging transactions through the central counterparty clearing services of the CME.  We offer a comprehensive summary of FINRA’s proposal.