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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, […]

Canada’s phase 5 mitigation map

Canada’s Office of the Superintendent of Financial Institutions (OSFI) is the first Regulator to break cover following BCBS\IOSCO’s 5 March statement. On 28 June the OSFI published a letter on its website, purporting to give guidance on the statement. For the convenience of its readers, the letter restates the BCBS\IOSCO statement, then goes on to […]

EMIR 2.0- indirect, possibly unintended, certainly consequential

Published in the OJ on 28 May, EMIR Refit entered into force on 17 June. Aimed at simplifying requirements and making obligations on smaller counterparties more proportionate, the Regulation is comprehensively summarised here. This short note focusses on one aspect of EMIR Refit’s key changes- its expansion of the scope comprised by “financial counterparty”. “Financial […]