The scope of products subject to the proposed margin requirements is not consistent across the EU, Japan and the US. The inconsistency in the margin product set raises problems for both VM and IM calculation, in addition to other cross-border situations. ISDA respectfully advises the regulators that for any counterparty pair, ISDA members intend to mitigate this issue by choosing whether to use a broader product set rather than the set required by any specific regulation, in order to ensure the parties capture all in scope products.