Rumoured welcome delay to WGMR “Phase 1.5”
The FT website is reporting unnamed sources which confirm that Council approval of the EU non-cleared margin rules will be slightly delayed until 21 November. The Council is relatively free from formal...
View ArticleThe ISDA 2016 Variation Margin Protocol: Boldly Going Where No Protocol Has...
The Final Frontier On 17 November 2016, ISDA published a “Supplemental Rules Exhibit” (the “EMIR Supplement”) to the ISDA 2016 Variation Margin Protocol (the “Protocol”). The purpose of the EMIR...
View ArticleEU non-cleared margin rules published in OJ
The long wait for EU non-cleared margin rules is finally over. Delegated Regulation (EU) 2016/2251 was published in the Official Journal this morning. Publication fires the starting gun for...
View ArticleISDA Tweaks Variation Margin Protocol
On 16 December 2016, ISDA published a revised supplement to the ISDA 2016 Variation Margin Protocol for EU non-cleared margin regulations (the “Revised EMIR Supplements”). The Revised EMIR Supplements...
View ArticleVariation Margin- a letter from the trenches
DRS is in the happy position of conducting variation margin negotiations for a number of large banks and asset managers, and well-placed to assess the current state of play. We are now 71 days from...
View ArticleStop the Bus! I Want to Get Off! More Changes to VM Protocol…
Introduction With VM CSA repapering in full swing over at DRS, this article took a while longer to write than first anticipated. It has now been two weeks since ISDA published another two supplemental...
View ArticleVM/IM Repapering: Learning the lessons from ‘Big Bang’
What did we learn? 1 March 2017 – deadline day for ‘big bang’ – has come and gone. We all breathed a sigh of relief. Or did we? Regulators recognised the fact that firms would not be compliant and,...
View ArticleEMIR = CFTC – better late than never
On 13 October 2017, the CTC and the EU announced substituted compliance determinations in respect of margin requirements for OTC derivatives. The determinations accept that the CFTC’s Final Margin Rule...
View ArticleFFX Margin- all that is solid melts into air
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...
View ArticleEU FFX – fiasco saga
On 24 November the European Supervisory Authorities (ESAs) released their long (in context) awaited forbearance announcement with respect to the margining or not of forward foreign exchange. A short...
View ArticleIMminent- the other elephant in the room
With a scant 28 days until the MiFID 2 starting gun sounds, Regulatory Change managers could be forgiven for looking forward to a well-deserved rest. In reality, 3 January 2018 will actually represent...
View ArticleFCA issues FFX outlook- fog confirmed
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...
View ArticleESMA updates EMIR Level 3- mainly reporting
ESMA updated its EMIR Q&A and MiFID 2 Q&A on Post-Trading Issues yesterday 14 December 2017. The updated Q&As include clarification in relation to: Indirect clearing – Q&A amended for...
View ArticleFFX Margin- the far off sound of a fat lady singing
The will they-won’t they soap opera of European FFX margin regulation is likely drawing to a close. As promised in their 24 November announcement, the three European Supervisory Authorities (ESMA, EBA...
View ArticleYet another Brexit article – life cycle events
Although we are reluctant to contribute to the now well-established industry of Brexit crystal ball-gazing, there are a number of documentation issues in which there is at least enough certainty to...
View ArticleBuilding Societies cleared to clear
The UK Government has amended the Building Societies Act to allow the societies and their subsidiaries to become clearing members. EMIR’s Category 4 clearing obligation will apply from 21 December...
View ArticleUS to EU- the honeymoon is over
Although prefaced by the usual caveat that “the views contained in this speech are my own and do not represent the views of the CFTC”, Commissioner Brian Quintenz delivered the keynote address...
View ArticleIM calculation change imminent-ish
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...
View ArticleCFTC nod and a wink for IM phase 5 depopulation
The CFTC’s Office of the Chief Economist (OCE) has responded to industry petitions to mitigate the widely-forecasted IM Phase 5 oncoming storm. Readers will recall the July 2018 ISDA/SIFMA white paper...
View ArticleWinter is coming…
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...
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