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It’s Official

17 February 2021. Delegated Regulations further amending the EMIR Margin RTS and amending the three Clearing Obligation RTS have today been published in the OJ. They will both enter into force on the following day- 18 February 2021. Amendments to the Margin RTS Extension of equity options derogation until 4 Jan 2024 Extension of intragroup […]

UK EMIR- tomAto tomAHto

This year’s “transition” period has inevitably devolved into a slow game of “Chicken”- it’s yet to be seen whether it will result in a complete car crash. Whatever the extension/shadow deal/no deal final outcome; the City and financial services have been excluded from consideration. Absent any imminent prospect of equivalence decisions; ISDA has yesterday published […]

Third (final) ESA report- brief Brexit novation window

On 23 November 2020, the Joint Committee of the European Supervisory Authorities (ESAs) published a third “final” version of its draft RTS making various amendments to EMIR margining requirements. The draft (re)introduces the following amendments: Levelling the international playing field: An extension of a further three years for the “temporary” exemption from margining requirements for single-stock […]

Increasingly IMminent

 ISDA CEO Scott O’Malia recently published a post exhorting the wider industry not to fall into the trap of complacency in respect of IM compliance. While Mandy Rice Davies’ “Well he would, wouldn’t he” might spring to the more flippant mind, the points are well made and worth underlining. On 3 April 2020, responding to […]

IM deferred by 1 year

On 3 April 2020 BCBS and IOSCO announced a one year extension to IM Phases 5 and 6. Accordingly, the revised Phase 5 deadline is 1 September 2021, Phase 6 is 1 September 2022. AANA calculation periods for each phase will also be extended by one year.   AANA Period (EU) Threshold Deadline Phase 5 […]

ISDA appeals IM

ISDA and 21 other Trade Associations (collectively “ISDA”) yesterday submitted a letter to regulators requesting a suspension of the IM Phase 5 and 6 deadlines, pending COVID-19 clarity. The letter also suggests that when and if new deadlines are set, “sufficient lead time be provided”.  The letter is supplemented by an article by Scott O’Malia, […]

EU finally confirms intent to IM mitigate

In the Regulatory equivalent of a pair of socks- necessary, entirely expected, but still welcome; the ESAs have today delivered an early Christmas present to Heads of Compliance in a draft Revised RTS echoing the July 2019 BCBS/IOSCO IM mitigation. Initial Margin          A revised article 36(1) instantiates the BCBS/IOSCO recommended bifurcation into two remaining IM […]

Singapore and Korea join rush to delay IM

The Korean Regulator, FSS, is the latest regulator to announce that they will adopt the BCBS/IOSCO guidelines for mitigating risk for non-cleared OTC contracts. This decision follows a recent publication by the MAS (Singapore’s regulatory authority) where they stated that they would also use BCBS/IOSCO’s framework for Non-Centrally Cleared Derivatives in determining whether margin requirements […]

IM- the breakdown (averted)

As expected, ISDA have communicated a more granular breakdown of estimates for the likely population of the new IM phases 5 and 6, via relevant working groups. These have been replicated and published by a number of third party firms. Although all the numbers are estimated, there seems to be both a lack of mathematical […]

IM Phase 5 to bifurcate

Confirming recent market rumours, BCBS\IOSCO have today announced their recommendation to stagger IM Phase 5 implementation over a two year period. An adjusted Phase 5 will apply to firms with an AANA equal to or greater than USD\EUR 50bn and less than 750bn. A new Phase 6, from 1 September 2020 to 1 September 2021, […]

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