ISDA member firms participating in the industry-led WGMR implementation initiative are concerned about the market’s ability to meet an implementation date of December 2015. This concern is based not only on the significant infrastructural changes required of market participants but also due to the significant coordination effort required of global regulators. In summary, ISDA proposed that rules become effective two years after rules are clarified and finalized in Europe, Japan, and USA. ISDA also proposed a phase-in schedule for upcoming Variation Margin (VM) requirements and urged regulators to avoid imposition of implementation dates during the year end code freeze periods. Based on the above, the practical start date of the WGMR requirements would be April 2017.
Documents (1) for ISDA letter to BCBS/IOSCO on timing issues for margin rules for uncleared derivatives
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ISDA In Review – August 2026
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in August 2026.
Remove Bureaucracy from Cross-margin Approvals
Cross-margining programs play a critical role in financial markets. By ensuring margin requirements more closely reflect the actual risk of a portfolio of products, they reduce liquidity strain and improve market efficiency, both of which will become even more important...
Joint Response on CCP Resolution
On September 7, ISDA and FIA responded to a Bank of England (BOE) discussion paper on central counterparty (CCP) resolution. The associations support greater clarity on valuation capabilities prior to a crisis scenario and the boundary between recovery and resolution,...
Expanding Legal Agreement Coverage in the CDM
This paper examines the recent extension of the Common Domain Model (CDM)1 to represent two of the most significant, and previously undeveloped, areas of its legal agreement model: umbrella agreements and contract amendments. Umbrella agreements are widely used to document...