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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 […]

IM Phase 5 mitigation…’ish

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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