BCBS IOSCO Revised UMR Timeline
https://drs-als.com/im-phase-5-to-bifurcate/A new phase 6 is introduced to spread the work for smaller firms to achieve compliance.
Some would argue that firms with an AANA of $8bn do not represent any sort of systemic risk to the capital markets. Even so they still need to exchange IM from 2021. BCBS IOSCO announced a revised timeline with a modified phase 5 and new phase 6, shown below.
As of now, no regulators have adopted this proposal, so in strict legal terms this timeline isn't something you can rely on, yet. For the announcement text follow this link, and for a summary of the proposal download the PDF attached below, and for the new timeline in PDF too.
Even with this revision, the time required to prepare for Phase 6 means smaller firms must still be on the ball for the 2020 deadline ($50bn AANA) otherwise they risk the same resource crunch as now.
Expect to see a slew of posts by law firms and consultancies on this new timeline! Best follow up so far is over at DRS here, which suggests the number of firms in each of the new phases.