SIFMA AMG requested relief for variation margin requirements applicable as of March 1, 2017 to counterparties not already included in phase 1 implementation of the uncleared swap margin requirements, namely counterparties with an average aggregate notional amount of non-centrally cleared derivatives below US$/EU€ 3 trillion. While all market participants, including asset managers, have endeavored to comply with the variation margin regulatory requirements scheduled to begin on March 1, asset managers continue to work through complex issues of application and interpretation, and are unable to fully utilize industry-wide efforts to standardize and automate required documentation. These challenges combined with limited dealer and custodian bandwidth has made it unlikely that the implementation efforts will cover all client needs by March 1.

SIFMA AMG has requested that all jurisdictions provide a transitional period beginning on March 1 to permit the rolling, prospective application of variation margin requirements, allowing market participants to make reasonable and continuous progress towards the exchange of variation margin. SIFMA AMG further requested additional time for FX products due to the concentration of work to be completed for those products. Finally, SIFMA AMG requested that regulators reassess the cross-border policies that are causing multiple jurisdiction’s requirements to apply to single transactions and single counterparty pairs.