ISDA advised firms on how to prepare for the implementation of initial margin ("IM") "Phase Five."
ISDA recommended that firms prepare by:
determining which entities will fall under the scope of IM requirements by calculating the indicative aggregate average notional amount ("AANA");
notifying any counterparties if the AANA calculations indicate that the firm's entities may fall under Phase Five; and
assessing whether the parties to a relationship may be eligible to delay the IM requirements by calculating the IM amount for the products subject to IM exchange.