In response to the global financial crisis of 2008-2009, the Group of 20 nations agreed to a financial regulatory reform agenda covering the over-the-counter derivatives markets and market participants, among them recommendations for the implementation of margin requirements for non-centrally cleared derivatives. The Basel Committee on Bank Supervision and International Organization of Securities Commissions subsequently developed and finalized their Final Framework on Margin Requirements for Non-Centrally Cleared Derivatives, which sought to establish international standards for such requirements, to be phased in over time.
As agreed in the revised implementation timeline to the final framework, the uncleared margin rules (UMR) began to be phased-in on September 1, 2016 for the largest market participants. Broader implementation of variation margin (VM) requirements occurred in March 2017, while initial margin (IM) requirements continue to phase-in annually through 2020.
The final phases of the UMR will occur on September 1 of 2019 and 2020, when a large number of additional counterparties will be brought into scope for IM requirements. The fundamental challenges for market participants during the final phases of IM implementation are distinct from and more intense than those experienced in previous phases, and therefore likely to result in broader systemic impact.
In this paper, ISDA and the Securities Industry and Financial Markets Association (SIFMA) seek to highlight the significant challenges market participants will encounter during the final phases of IM implementation and identify the key tasks and resulting hurdles that must be overcome to ensure an orderly implementation that avoids disruption to the functioning of the derivatives market.
Documents (1) for Initial Margin for Non-Centrally Cleared Derivatives: Issues for 2019 and 2020
Latest
ISDA Response – ROC Consultation on Revised CDE Version 4
The International Swaps and Derivatives Association, Inc. (ISDA) response to the Regulatory Oversight Committee (ROC) consultation on the harmonisation of critical OTC derivatives data elements (CDE) revised CDE Technical Guidance – version 4, submitted to the ROC on January 24,...
ISDA response to ESMA MiFIR Review Consultation
On July 11, ISDA submitted a response to the European Securities and Markets Authority's (ESMA) fourth package of Level 2 consultation under the Markets in Financial Instruments Regulation Review (MiFIR), on transparency for derivatives, package orders and input/output data for...
Canadian Transaction Reporting Party Requirements
These Reporting Party Requirements establish the hierarchy and tie-breaker logic to determine a single reporting counterparty for Canadian provincial reporting. By leveraging the existing reporting party standard established for reporting to the CFTC, in most cases these rules facilitate submission...
ISDA In Review – June 2025
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in June 2025.