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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, […]

OSFI verifies their IM Delay requirements

The spread of COVID-19 has not stopped the OSFI of Canada from verifying their IM arrangements. As was previously covered, the OSFI of Canada has issued a revised version of its Margin Requirements for Non-Centrally Cleared Derivatives. Since BCBS’s March 2019 announcement, the OSFI was the first regulator to announce that they would be extending […]

CFTC confirms Libor Relief

At the request of the ARRC, the CFTC has today announced comprehensive relief to swap dealers and other market participants as they make the transition from swaps that reference LIBOR and other “Impaired Reference Rates” to those that reference alternative benchmarks. The relief comprises no-action letters from each of the Commission’s main divisions, broadly covering […]

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 […]

Prudential Regulators do the prudent thing

US’ Prudential Regulators (FDIC, Federal Reserve, FDIC, OCC, FHFA and FCA) have become the latest to issue a proposal for amending Swap Margin Requirements. The CFTC was the first regulator to adopt the BCBS’ mitigation recommendations, staggering the ‘Big Bang’ Phase 5 and 6 thresholds, so it was only a matter of time for the […]

Another week, another regulator falls in line

The latest IM deadline passed at the start of this month without fanfare, and larger firms were able to breathe their fourth sigh of relief. A year from now, the challenge will not be as “easy”. In Phase 4, approximately 35 firms fell in-scope of the €750 bn threshold. Updated numbers for Phase 5 show […]

Margin Xchange…we hardly knew you

Highlander 1986, “There can be only one!” or for a younger generation, “When you play the game of thrones, you win or die”. Risk magazine reports that MarginXchange (MX) has retired from the fray, leaving an open (if depleted) field for its erstwhile rival ISDACreate (IC). MX was established by the triumvirate of Allen & Overy, […]

HKMA latest IM domino to fall

Earlier today, the Hong Kong Monetary Authority announced their intention to adopt the BCBS/IOSCO’s revised implementation schedule. Their updated deadlines are as follows: For target institutions with Non-Cleared OTC derivatives of more than HKD 375 billion the date will be 1 September 2020. For target institutions with Non-Cleared OTC derivatives of more than HKD 60 […]

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