Final Implementation Phases of Initial Margin for Uncleared Derivatives Set for Deferral

With this extension:

• The Phase 5 compliance date applicable to entities with an aggregate average notional amount (AANA) of €50 billion/$50 billion or greater will be moved from September 1, 2020, to September 1, 2021.
• The Phase 6 compliance date applicable to entities with an AANA of €8 billion/$8 billion or greater will be moved from September 1, 2021, to September 1, 2022.

Global regulators will need to adopt this updated timeline in connection with their respective margin rules for it to take effect, but it is expected they will follow suit.

¹Basel Comm. on Banking Supervision & Int’l Org. of Sec. Comms., IOSCO MR/07/2020, Basel Committee and IOSCO Announce Deferral of Final Implementation Phases of the Margin Requirements for Non-Centrally Cleared Derivatives (Apr. 3, 2020), https://www.iosco.org/news/pdf/IOSCONEWS560.pdf.

²Int’l Swaps & Derivatives Ass’n et al., Letter re: Margin Requirements for Non-Centrally Cleared Swaps Margin – Impact of COVID-19 on Initial Margin Phase-In (Mar. 25, 2020), https://www.isda.org/a/sM7TE/IMPhase5-6COVID-19Letter.pdf.