The timeline under which firms are impacted depends on their “aggregate average notional amount” (AANA) of non-centrally cleared derivatives (at consolidated group level) falling above a pre-determined regulatory threshold. The compliance process is complex and can take from 6 to 9 months on average in our experience. However, initial margin rules have many specificities, due to the nature of the calculation of the IM amounts, the principle of bilateral exchange of margin (each party posts and receives at the same time), the possible relief with the €50 million threshold and custodial segregation aspects. Changing rules for non-centrally cleared derivativesĮxchanging initial margin (IM) on non-cleared derivative trades is now an established practice, at least for the firms that have fallen under the scope of the rules in their earlier phases (1 to 5). Phases 6 (September 2022) is still ahead and will impact a significant number of firms, including institutional investors. ![]() ![]() ![]() As the rules are phased-in, increasing numbers of market participants are subject to the requirements every year.
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