IM

Prudential Regulators do the prudent thing

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US’ Prudential Regulators (FDIC, Federal Reserve, FDIC, OCC, FHFA and FCA) have become the latest to issue a proposal for amending Swap Margin Requirements.

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Another week, another regulator falls in line

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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”.

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Margin Xchange…we hardly knew you

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Highlander 1986, “There can be only one!” or for a younger generation, “When you play the game of thrones, you win or die”.

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HKMA latest IM domino to fall

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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:

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Singapore and Korea join rush to delay IM

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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.

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ISDA Applies Further French Twist to IM Documentation

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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 greater choice.

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How Pre-Trade IM Calculation can optimize margin and reduce collateral drag

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The advent of the Uncleared Margin Rules (UMR) has not only put pressure on firms to make their systems compliant with the regulations, but has also put a drag on real returns as a result of the increased need to ... Read More

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IM- the breakdown (averted)

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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 both a lack
of mathematical rigour and some confusion between the population and threshold
estimates.

The estimates are as follows:

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IM Phase 5 to bifurcate

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Confirming recent market rumours, BCBS\IOSCO have today announced their recommendation to stagger IM Phase 5 implementation over a two year period. An adjusted Phase 5 will apply to firms with an AANA equal to or greater than USD\EUR 50bn and less than 750bn.

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Phase 5 mitigation mitigated

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Trailing in the wake of their northern neighbours, the CFTC have today issued a Staff Advisory confirming that there is no requirement for covered swap entities (CSEs) to put IM documentation and custody arrangements in place before the $50m threshold is reached.  As the conclusion to the Advisory notes:

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