Each September until 2022*, increasing numbers of entities will be required to meet initial margin regulations as the threshold level for compliance reduces. Preparation for meeting these requirements will take significant time, and will involve intensive work to ensure systems, processes and documentation are in place.
ISDA has published a fact sheet that sets out the steps firms should take when preparing to comply with regulatory initial margin requirements. These are not necessarily presented in chronological order – the precise order and timing will depend on a firm’s specific circumstances.
STEP 1: Identify in-scope entities early
STEP 2: Make early disclosures to counterparties
STEP 3: Exchange information on compliance
STEP 4: Identify special cases
STEP 5: Establish custodial relationships
STEP 6: Prepare for compliance
STEP 7: Negotiate/execute documentation
STEP 8: Finalize preparations
Updated in August 2020 to account for new Basel Committee on Banking Supervision/IOSCO implementation schedule.
Click on the PDF below to read the full list of steps.