SIFMA provided notice to banking regulators (the Board of Governors of the Federal Reserve, the Office of the Comptroller of the Currency and the FDIC) of a forthcoming change in the treatment of variation margin payments for over-the-counter derivatives by central clearing counterparties ("CCPs"). Historically, variation margin payments have been treated as collateral for outstanding exposure, a treatment that a SIFMA comment letter refers to as the "collateralized to market" ("CTM") model. Going forward, the CCPs will adopt a model by which variation margin payments are treated as settlement

ISDA CEO Scott O'Malia warned that there might not be sufficient time for dealers and their clients to meet the March 1, 2017 variation margin deadline for non-cleared derivatives.

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."

Trade associations urged U.S. regulators to provide guidance on implementing BCBS-IOSCO recommended exemptions from swaps margin requirements where the amounts to be transferred are below relevant thresholds.

ISDA identified key differences among jurisdictional implementations of margin requirements for non-cleared derivatives that have led to market fragmentation.