The International Swaps and Derivatives Association, Inc. (ISDA) today published the following statement regarding the revised implementation date for non-cleared derivatives margin rules:
“ISDA very much welcomes the extension to the start date for non-cleared derivatives margin rules. The new rules will require firms to make significant changes to their infrastructure, technology, processes and documentation. Firms have been working hard to prepare for the rules, but the changes would have been all but impossible to complete by the original December 2015 effective date, particularly as final rules have not yet been published by US, European and Japanese authorities.
“While still challenging without final rules, the revised implementation date should give firms additional time to develop, implement and test new systems. We are grateful that regulators have listened to concerns expressed by ISDA and other market participants on this issue. We urge the national regulators to publish the final rules as soon as possible, and we look forward to working closely with the regulators over the coming months,” said Scott O’Malia, ISDA Chief Executive Officer.
Background
The final framework for non-cleared derivatives margining was published in September 2013 by the Working Group on Margining Requirements (WGMR), a body jointly run by the Basel Committee on Banking Supervision and International Organization of Securities Commissions (IOSCO). European, Japanese and US authorities subsequently published proposed national rules in April, July and September 2014, respectively. Final national rules have not yet been published.
These proposals set a phased implementation schedule for initial margin, starting from December 1, 2015 for the largest derivatives users and extending through to December 2019. Variation margin requirements, however, were scheduled to come into force for all covered entities on December 1, 2015.
In its letters to the European Supervisory Authorities (July 14, 2014), the Basel Committee and IOSCO (August 18, 2014), and US Prudential regulators and the Commodity Futures Trading Commission (November 24, 2014), ISDA requested that the industry be given two years to prepare from the point that final regulations are published by US, European and Japanese authorities. ISDA also proposed a phased-in implementation for variation margin, starting with the largest and most systemically important derivatives users.
ISDA has played a leading role in helping the industry prepare for non-cleared margin rules through its ISDA WGMR implementation effort. A major part of the initiative is the development of a standard model for calculating initial margin, called the ISDA SIMM. ISDA has been working to revise standard collateral documentation so it is compliant with the new margin rules, as well as develop and define standard business and technology practices for margin calculations, notifications and settlement, collateral eligibility and segregation.
Details about ISDA’s WGMR initiative, as well as an ISDA webcast on the topic, can be found on the ‘ISDA WGMR Implementation’ section of the website.
