Assets “not readily convertible into cash” are excluded in calculating net capital for a broker-dealer. SEC Division of Trading and Markets Staff last week took a no-action position that margin collateral posted by a broker-dealer to a DCO for a cleared swap need not be excluded in calculating net capital. Furthermore, even if the swap is not cleared, the initial margin need not be excluded if certain requirements are met. Variation margin on a non-cleared swap, however, must be excluded.