excellent post on UMR from DRS - a must read for any firm who might be in Phase 4 or 5. Bill
Rising to the repapering challenges of IM Phases 4 and 5 Introduction 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 […]
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) […]
Derivatives trading and processing are becoming more automated, but the legal documents that back these trades are still reliant on paper and wet signatures. This slows down the time it takes to negotiate a document, and creates inefficiencies throughout the whole process.
In response to the global financial crisis of 2008-2009, the G20 agreed to a financial regulatory reform agenda covering the over-the-counter derivatives markets and market participants, among them recommendations for the implementation of margin requirements for non-centrally cleared derivatives.
Bill: The PDF provided on the ISDA website examines refinements to the way IM is calculated for uncleared business. It links market size and liquidity to portfolio size and closeout timing to make the amount of IM more proportional to the size and risk in a given portfolio. According to Risk magazine this paper bypassed the ISDA WGMR causing some concern. At the moment the paper is purely academic and isn't a change to SIMM but more a discussion paper for global regulators.
The September 2019 Uncleared Margin deadline (and the 2020 date) will bring many more firms in-scope for exchanging IM. Both ISDA with LinkLaters, A&O with Markit and SmartDX are in the process of launching platforms to dramatically simplify the process of negotiating and implementing the necessary agreements. The A&O platform was announced in April here, we now have a high level description of the ISDA platform in the attached PDF and description below.
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. 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.
Each September until 2020, increasing numbers of entities will be required to meet initial margin regulations as the threshold level for compliance reduces. Preparation for meeting these requirements will take significant time, and will involve intensive work to ensure systems, processes and documentation are in place.
The FCA have today issued their response to the ESAs 24 November FFX announcement. It is brief and is worth reading in full as a masterclass in ironic prevarication and understatement. Highlights below (emboldening is ours): “The amendments to the RTS should become increasingly clear over time and we would expect firms to make their […]
A brief spotlight through the fog swirling around the upcoming obligation to exchange margin on forward foreign exchange. There was a widespread, if only whispered, expectation that a 7/8 November ESMA Board of Supervisors meeting would result in an official announcement of forbearance. While the EU has no equivalent mechanism to the CFTC’s enthusiastic use […]