The phase-five initial margin (IM) calculation period in the US is June-August 2019, and not March-May 2020 as in other jurisdictions. The US non-cleared margin regulations require an earlier calculation period than other jurisdictions to determine whether a party is in-scope for initial margin.

To assist market participants that may be subject to the phase-five IM requirements in the US, ISDA has prepared an informational document that summarizes and explains the requirements for calculating the average aggregate notional amount (AANA) for phase-five between June 1 and August 31, 2019 for a compliance date of September 1, 2020.