Tag: IM
Singapore and Korea join rush to delay IM
The Korean Regulator, FSS, is the latest regulator to announce that they will adopt the BCBS/IOSCO guidelines for mitigating risk for non-cleared OTC contracts. This decision follows a recent publication by the MAS (Singapore’s regulatory authority) where they stated that they would also use BCBS/IOSCO’s framework for Non-Centrally Cleared Derivatives in determining whether margin requirements […]
ISDA applies further French twist to IM documentation
Last July, ISDA decided to add French and Irish law to our library of Master Agreements in an attempt to prepare for potential Brexit complications. As mentioned in our earlier post, the objective of this is not to undermine English and New York law, but merely to offer an alternative so firms are awarded a […]
Winter is coming…
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 not, the countdown has already begun. Why worry about it now? The classic […]
IMminent- the other elephant in the room
With a scant 28 days until the MiFID 2 starting gun sounds, Regulatory Change managers could be forgiven for looking forward to a well-deserved rest. In reality, 3 January 2018 will actually represent the beginning of a long process of clarification, refinement and final implementation. In this slightly dispiriting context, it is not surprising that […]
ISDA Publishes WGMR Compliant VM CSAs
Introduction On 14 April 2016 ISDA published the New York law “2016 Credit Support Annex for Variation Margin (VM)” (the “NY-law VM CSA”). Subsequently, on 29 April 2016 it published the English law “2016 VM Credit Support Annex for Variation Margin (VM)” (the “English-law VM CSA” and together with the NY-law VM CSA, the “VM […]
Margin rules delay is in the air
The industry’s call for a delay in the margin rules, expected to apply from 1 December 2015, may finally receive a positive response from the regulators[1]. These rules on risk-management of uncleared derivatives will impose collection of Initial Margin (IM) and Variation Margin (VM). The global phase-in timeline was set by the Basel Committee on […]
Cross-currency collateral ousted from SCSA 2
On 6 November 2014, ISDA released the 2014 “Standard” Credit Support Annex, available as always under English law or New York law. This new CSA is meant to coexist with the legacy 1994 CSA and the already out-of-fashion 2013 CSA published only a year ago. What was presented as a tour de force in the […]
ISDA Still Swinging in the Fight Over Initial Margin for Non-Centrally Cleared Derivatives
On 12 April 2013, the International Swaps and Derivatives Association (ISDA) published a Letter on Margin Requirements for Non-Centrally Cleared Derivatives written jointly with the Institute of International Finance (IIF), the Association of Financial Markets in Europe (AFME) and the Securities Industry and Financial Markets Association (SIFMA). The letter is addressed to the Basel Committee […]
IOSCO publishes responses to consultation on margin requirements for non-cleared derivatives
On 2 April 2013, the International Organization of Securities Commissions (IOSCO) published a list of the responses it received to its consultation document on margin requirements for non-centrally cleared derivatives, published on 15 February 2013, a more detailed summary of which can be found here. Two notable responses were received from ISDA (primarily for the […]