Non-cleared Derivatives

Banks have spent the last four years gamely preparing for and complying with IM regulations. Phases 1-3 have been challenging, the current phase 4 promises more of the same. The market has long been aware that phases 1-4 are mere kittens to the phase 5 (probably angry) tiger. Useful initiatives- negotiation platforms, custodian portals, standardised […]

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January 30th, 2019 by Nick Railton-Edwards Tags: , , ,

DRS recently hosted a well-attended IM Breakfast Roundtable at the Gherkin. A distinguished list of panellists included Mayer Brown’s Ed Parker, Margin Reform‘s Chetan Joshi and Bank of New York Mellon’s Mark Higgins. Focused primarily on the imminent challenges of IM Phase 4, participants were drawn from the sellside; the event’s success effectively mandates a […]

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December 5th, 2018 by Nick Railton-Edwards Tags: , , , ,

Rising to the repapering challenges of IM Phases 4 and 5   Introduction The deadline for compliance with Phase 4 and Phase 5 of the IM requirements is miles away, isn’t it?  Isn’t it…? The truth is that, whether you like it or not, the clock is already ticking.  Whether anyone has told you or […]

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The CFTC’s Office of the Chief Economist (OCE) has responded to industry petitions to mitigate the widely-forecasted IM Phase 5 oncoming storm. Readers will recall the July 2018 ISDA/SIFMA white paper previewing the phase 5 population explosion and recommending various reduction strategies: • Raising the in-scope AANA threshold from $8bn. to $100bn. • Postponing mandatory […]

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As market participants are all too aware, following the financial crisis in 2008-2009, G20 agreed to a regulatory reform agenda covering the OTC derivatives market and market participants, including proposals for margin requirements for non-centrally cleared derivatives. The recommendations were finalised in the BCBS-IOSCO’s Final Framework for Non-Centrally Cleared Derivatives, which established the international standards […]

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In the previous article, Custody 101 C, we commenced the review of the various things that can happen during the regular course of holding your clients’ securities under custody. That entire article dealt with financial activities; income and capital payments related to the securities. This article will review various regular events that can take place […]

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February 19th, 2018 by Torsten Krebs Tags:

Introduction The first article provided a high-level review of the parties, the agreement, accounts and assets involved in the most standard of custody relationships: namely a commercial bank providing global custody to local institutional investors and local market sub-custody to global custodians from other jurisdictions [= “you” in these articles]. It can be observed in […]

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On 5 February the five US Prudential Regulators jointly issued a proposal to ensure that certain mandatory amendments to legacy contracts would not trigger their inclusion under the margin regime. The vast majority of jurisdictions contain anti-evasion measures in their margin rules, to the effect that material amendments to pre-margin, legacy trades will act to […]

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The will they-won’t they soap opera of European FFX margin regulation is likely drawing to a close. As promised in their 24 November announcement, the three European Supervisory Authorities (ESMA, EBA and EIOPA) published a draft amendment to the EMIR Margin RTS. The amendment does clarify matters by excising the announcement’s “most likely”, confirming that […]

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December 8th, 2017 by Nick Railton-Edwards Tags: , , ,

The FCA have today issued their response to the ESAs 24 November FFX announcement. It is brief and is worth reading in full as a masterclass in ironic prevarication and understatement. Highlights below (emboldening is ours): “The amendments to the RTS should become increasingly clear over time and we would expect firms to make their […]

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