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Threshold monitoring – IM panacea?

As the number of newly in-scope IM entities is set to explode, the possibility of threshold monitoring has the potential to ease what will be a huge effort across all in-scope market participants to meet the new Phase 5 and 6 deadlines. Properly implemented, threshold monitoring imposes its own significant legal and operational challenges. The potential upside is that, if newly in-scope participants estimate that their IM exposure will not approach the EUR 50 million threshold, threshold monitoring could avoid, or postpone, the need to open custodial accounts and put in place IM documentation