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.
ISDA CEO Scott O'Malia encouraged regulators and policymakers to reduce certain "burdensome" requirements that will be enacted on the forthcoming implementation of initial margin "Phase Five."
CFTC Chair J. Christopher Giancarlo urged U.S. regulators to clarify obligations for dealers to exchange initial margin where requirements are below the $50 million threshold amount specified in the rules.