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March 26, 2020

Should Phase 5 of UMR Be Delayed? What do 21 Trade Associations Think?

Should Phase 5 of UMR be Delayed? The September 2020 deadline isn't far away. Is the impact of the virus a material change to the ability of firms to prepare? Hear what 21 trade associations think.

What do you think? Are the current circumstances a strong enough justification to delay the September 2020 deadline for the Uncleared Margin Regulations? From a systemic risk point of view, you could argue that the current market conditions make it even more important that firms who should be exchanging IM actually do so. From a project management point of view, it may be pretty hard to deliver the changes to governance, systems and procedures necessary to be ready in September.

A joint letter (attached below) from 21 trade associations plead for more time. There's no single reason, only that the scope of preparations including legal, custody and regulatory approvals for the 3,616 firms involved may overwhelm the available people.

Let us know what you think on LinkedIn, is this a justifiable move? Will the regulators take pity, or be more scared of the outcome if IM is delayed?

More to read:

  • ISDA blog post: https://www.isda.org/2020/03/26/coronavirus-delay-to-im-deadlines-necessary/
  • DRS commentary: https://drs-als.com/isda-appeals-im-2/
  • Joint letter (attached below)

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