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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 […]

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 […]

12th EMIR Q&A update

On 31 March 2015, ESMA published its 12th Q&A on EMIR implementation. Since the previous Q&A dated 24 October 2014, ESMA provided further clarification on the following issues: OTC Questions: Intragroup transactions Status of sovereign funds Pension Scheme exemption from the clearing obligation Frontloading requirement and intragroup transactions exemption Clearing obligation in relation with trade novations […]

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 […]

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 […]

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