Category: IM
OSFI verifies their IM Delay requirements
The spread of COVID-19 has not stopped the OSFI of Canada from verifying their IM arrangements. As was previously covered, the OSFI of Canada has issued a revised version of its Margin Requirements for Non-Centrally Cleared Derivatives. Since BCBS’s March 2019 announcement, the OSFI was the first regulator to announce that they would be extending […]
CFTC confirms Libor Relief
At the request of the ARRC, the CFTC has today announced comprehensive relief to swap dealers and other market participants as they make the transition from swaps that reference LIBOR and other “Impaired Reference Rates” to those that reference alternative benchmarks. The relief comprises no-action letters from each of the Commission’s main divisions, broadly covering […]
EU finally confirms intent to IM mitigate
In the Regulatory equivalent of a pair of socks- necessary, entirely expected, but still welcome; the ESAs have today delivered an early Christmas present to Heads of Compliance in a draft Revised RTS echoing the July 2019 BCBS/IOSCO IM mitigation. Initial Margin A revised article 36(1) instantiates the BCBS/IOSCO recommended bifurcation into two remaining IM […]
Prudential Regulators do the prudent thing
US’ Prudential Regulators (FDIC, Federal Reserve, FDIC, OCC, FHFA and FCA) have become the latest to issue a proposal for amending Swap Margin Requirements. The CFTC was the first regulator to adopt the BCBS’ mitigation recommendations, staggering the ‘Big Bang’ Phase 5 and 6 thresholds, so it was only a matter of time for the […]
Another week, another regulator falls in line
The latest IM deadline passed at the start of this month without fanfare, and larger firms were able to breathe their fourth sigh of relief. A year from now, the challenge will not be as “easy”. In Phase 4, approximately 35 firms fell in-scope of the €750 bn threshold. Updated numbers for Phase 5 show […]
Margin Xchange…we hardly knew you
Highlander 1986, “There can be only one!” or for a younger generation, “When you play the game of thrones, you win or die”. Risk magazine reports that MarginXchange (MX) has retired from the fray, leaving an open (if depleted) field for its erstwhile rival ISDACreate (IC). MX was established by the triumvirate of Allen & Overy, […]
HKMA latest IM domino to fall
Earlier today, the Hong Kong Monetary Authority announced their intention to adopt the BCBS/IOSCO’s revised implementation schedule. Their updated deadlines are as follows: For target institutions with Non-Cleared OTC derivatives of more than HKD 375 billion the date will be 1 September 2020. For target institutions with Non-Cleared OTC derivatives of more than HKD 60 […]
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 […]
IM- the breakdown (averted)
As expected, ISDA have communicated a more granular breakdown of estimates for the likely population of the new IM phases 5 and 6, via relevant working groups. These have been replicated and published by a number of third party firms. Although all the numbers are estimated, there seems to be both a lack of mathematical […]