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Margin for Non-Cleared OTC

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 […]

Knights (and ladies) of the Roundtable

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 […]

Aussie IM Phase 4 double whammy

Bill: More work for Phase 4 UMR, if we're unlucky.


Opinions obviously vary, but for me there are very few opportunities to be glad not to be Australian. Here is one for already punch-drunk IM lawyers and compliance personnel. The largest four banks in New Zealand are Australian-owned- ANZ, ASB, BNZ and Westpac. New Zealand is not a G20 member and has therefore been (relatively) […]

CFTC nod and a wink for IM phase 5 depopulation

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 […]

Brexit – Contractual Dis-Continuity

A long and comprehensive post from DRS on Brexit and the OTC market, follow the link below.


A question that has been ignored, until very recently, is how firms will deal with cross-border derivative contracts when the UK leaves the EU in March 2019. Leaving the single market without either EEA membership or a trade agreement covering financial services, will result in complications for existing derivative contracts. With approximately £26 trillion of outstanding […]

ISDA presses the panic button on IM

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 […]

 

Click the link below for the full article - useful in parallel to our earlier papers and the one from ISDA. Bill.

ISDA presses the panic button on IM

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 […]

CFTC to simplify segregation

July 24th saw a unanimous approval of the CFTC’s proposal to reduce the complexity surrounding segregation of assets held as collateral in uncleared swap transactions. Under the Dodd-Frank, a swap dealer was required to notify each counterparty that they (the counterparty) possessed the right to choose whether that to keep their funds in a segregated […]

IM calculation change imminent-ish

There is mounting pressure to revisit a fundamental aspect of the IM calculation methodology. The BCBS-IOSCO 2015 framework mandates an IM determination based on a 99% VAR over a fixed 10 day liquidation horizon[1]. ISDA have published a paper by Professor Rama Cont, Chair of Mathematical Finance at Imperial College London, which advocates for a […]

The blog post at DRS comments on the paper from the CFTC that fundamentally revisits how risk is measured and managed in the uncleared market. Worth a read, Bill.

Custody 101 B

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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