On 28 June 2022, the UK’s Prudential Regulation Authority (PRA) published a letter to the Chief Risk Officers of banks operating under its jurisdiction. The letter details its review of the market’s use of ISDA’s Standard Initial Margin Model (SIMM); the review was intended to assess the SIMM’s performance during recent periods of market stress […]

The PRA and FCA yesterday published a joint policy statement on margin requirements for non-centrally cleared derivatives, making amendments to Binding Technical Standard BTS 2016/2251. The amendments temporarily extend the period during which EEA UCITS are eligible collateral under the UK margin regime, until end-December 2022. “2.9 The PRA has given due regard to the […]

The PRA and FCA yesterday launched a joint consultation on whether to align UK EMIR margin requirements with the rest of the world and continuing market practice. One would hope that if any responses are received by the 19 May 2021 deadline, they would be unanimously supportive. The consultation covers the following aspects: IM phase- […]

Risk magazine (paywalled) are today reporting that over half of phase 5 IM new entrants may fail to meet custodian deadlines, potentially rendering them unable to trade on the 1 September 2021 deadline. Widely predicted and warned against at the time, a large number of firms took the April 2020 extension as an invitation to […]

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 […]

The CFTC have published the final rule extending IM Phase 6 in today’s Federal Register. In response to the COVID-19 pandemic, the final rule extends the Phase 6 deadline by one year to 1 September 2022 and has a retrospective effective date of 9 December 2020. The final rule updates the April 2020 “final” rule […]

 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 […]

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 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, […]