SIFMA Submits Comments to the BCBS and IOSCO on the Consultative Document on Margin Requirements for Non-Centrally-Cleared Derivatives

SIFMA has published comments to the Working Group on Margining Requirements (WGMR) of the Basel Committee on Banking Supervision (BCBS) and IOSCO on the Consultative Document on margin requirements for non-centrally-cleared derivatives. This letter includes a proposed universal two-way initial margin requirement aimed at ensuring that interconnected intermediaries have sufficient resources to withstand a major counterparty default without transmitting the resulting losses to third parties.

SIFMA further recommends suggestions regarding:

• Segregation of initial margin;
• Cross-margining and netting arrangements;
• Eligible collateral for margin;
• The application of margin requirements to transactions with affiliates;
• Structured finance SPVs;
• Non-financial end users and sovereign entities; and
• Certain cross-border issues.

View comment letter here (links externally to SIFMA website). MFA also submitted comments (in today's news). ISDA had previously submitted comments.