ISDA expresses its concern for the implementation of uncleared OTC derivatives margin rules in December 2015

ISDA expressed its concern for the implementation of uncleared OTC derivatives margin rules in December 2015, through a letter sent to BCBS & Basel Committee on Banking Supervision (BCBS) and the International Organization of Securities Commissions (IOSCO).

The international banking industry has called for a two-year delay to upcoming margin rules for uncleared derivatives, highlighting a number of implementation issues facing market participants attempting to comply with the oncoming regulatory demands. 

ISDA also requested that the introduction of variation margin (VM) rules be phased in over time. This specific request for the VM is backed up by the argument that if all market participants need to be fully compliant on a single date, this would be potentially systemically dangerous. ISDA also fear that smaller market participants will be left out of the market, thus there should be a mechanism to ensure that the non-systemic market participants are able to remain competitive. 

ISDA & IOSCO both declined to comment on the letter's content as Reuters reported in their post "Banks push for delay to introduction of derivatives rules" yesterday. The letter referred to in the Reuters article is attached below.

Maria L.