ISDA, SIFMA, GFXD and SIFMA AMG are requesting that US regulators provide clarification that covered swap entities and their counterparties that will become subject to the initial margin requirements of the Margin and Capital Requirements for Covered Swap Entities or the Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants as of September 1, 2019 (phase four) and on or after September 1, 2020 (phase five) do not have to comply with the documentation requirements described therein unless the bilateral IM amount exceeds $50 million.

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