Body of Law:
The ISDA summary is a useful reminder to market participants with significant derivatives activities - and those with affiliates with significant derivatives activities - that determining whether IM requirements will apply in September 2020 requires tracking activities for the upcoming months of this year. As previously highlighted, firms should also bear in mind that this counting exercise may be just one of many to be done, given that the U.S. requirements differ from other jurisdictions, perhaps most notably in the time period during which counting is required (in Europe, for example, the period is March-May 2020).