Skip to content

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 […]

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 […]

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 […]

Bailey’s freshest tips for the Brexit Break-Up

Earlier this week, the Chief Executive of the FCA, Andrew Bailey provided us with a recent update about the current state of affairs regarding Brexit. As is fast becoming the norm in Bailey’s Brexit updates, he opened his speech with the progress that has been made thus far; the Temporary Transitional Power regime; the signing […]

ISDA Consultation – The results are in…

In May 2019, ISDA launched two consultations: one addressing adjustments to fallback rates if IBORs are permanently discontinued, and another to address the pre-cessation of LIBOR and other IBORs. The operationally imminent cessation of LIBOR can hardly be classified as breaking news. The light shone by the 2008 financial crash fatally exposed the benchmark’s fragility, […]

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 […]

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, […]

Phase 5 mitigation mitigated

Trailing in the wake of their northern neighbours, the CFTC has today issued a Staff Advisory confirming that there is no requirement for covered swap entities (CSEs) to put IM documentation and custody arrangements in place before the $50m threshold is reached.  As the conclusion to the Advisory notes: “Accordingly, to the extent the $50 […]

Press enter or esc to cancel