Remaining Stage of Initial Margin Phase-In for the Margin Requirements for Non-Centrally Cleared Derivatives

Published on:
September 13, 2019
Submitted to:
Multiple Agencies
Submitted by:
SIFMA AMG

Summary

SIFMA’s Asset Management Group (SIFMA AMG) submitted a letter to global and U.S. Regulators in regards to several scoping and implementation issues that asset managers and their clients are facing in the remaining phases of the implementation of the initial margin requirements for non-centrally cleared derivatives (“UMR”). The AMG letter is supportive, and appreciative of, regulator action aimed at easing implementation burdens associated with the final phases of the UMR implementation.  However, AMG believes there are additional scoping and implementation challenges presented by the UMRs on asset managers and their clients and SIFMA AMG respectfully requested that regulators consider additional actions to address these as specified in our letter

Excerpt

September 13, 2019

Secretariat of the Basel Committee on Banking Supervision Bank for International Settlements

Secretariat of the International Organization of Securities Commissions

Board of Governors of the Federal Reserve System

European Banking Authority

European Central Bank

European Commission

European Securities and Markets Authority

Farm Credit Administration

Federal Deposit Insurance Corporation

Federal Housing Finance Agency

Financial Conduct Authority

Office of the Comptroller of the Currency

U.S. Commodity Futures Trading Commission

U.S. Department of the Treasury

U.S. Securities and Exchange Commission

Australian Prudential Regulation Authority

Brazil National Monetary Council

Canada Office of the Superintendent of Financial Institutions

Central Bank of Brazil

Central Bank of Ireland

Hong Kong Monetary Authority

Japan Financial Services Agency

Luxembourg Commission de Surveillance du Secteur Financier

Monetary Authority of Singapore

Korean Financial Supervisory Service

Swiss Financial Market Supervisory Authority

South African Prudential Authority

South African Financial Sector Conduct Authority

Re: Margin Requirements for Non-Centrally Cleared Derivatives – Remaining Stages of Initial Margin Phase-In

Dear Sirs and Madams:

The Asset Management Group of the Securities Industry and Financial Markets Association (“AMG”)1 is writing in regards to several scoping and implementation issues that asset managers and their clients are facing in the remaining phases of the implementation of initial margin (“IM”) requirements for non-centrally cleared derivatives (commonly referred to as the “Uncleared Margin Rules” or “UMRs”).

We support the recent July 23, 2019 joint statement of the Basel Committee on Banking Supervision (“BCBS”) and the International Organization of Securities Commissions (“IOSCO”) (the “July 23, 2019 Statement”) recommending extending implementation of the remaining phases of the UMRs (by splitting Phase V into two phases). We encourage global regulators to adopt the July 23, 2019 Statement for regulatory certainty and clarity.2 In particular, and consistent with the July 23, 2019 Statement, an intermediary phase-in period between Phase IV and Phase V set at an amount above EUR/USD 50 billion3 would allow market participants and regulators to assess and hopefully address difficulties in implementation prior to the rush of counterparties coming within scope at the EUR/USD 8 billion threshold,4 and would allow for the tapered development of market infrastructure necessary for successful compliance.

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1 SIFMA AMG brings the asset management community together to provide views on U.S. and global policy and to create industry best practices. SIFMA AMG’s members represent U.S. and global asset management firms whose combined assets under management exceed $45 trillion. The clients of SIFMA AMG member firms include, among others, tens of millions of individual investors, registered investment companies, endowments, public and private pension funds, UCITS and private funds such as hedge funds and private equity funds.

2 We applaud the Farm Credit Administration, the Federal Deposit Insurance Corporation, the Federal Housing Finance Agency, the Office of the Comptroller of the Currency (U.S. Department of the Treasury), the Board of Governors of the Federal Reserve System

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