On November 16, ISDA published a document that looked at proposal 6 in the final Basel Committee on Banking Supervision (BCBS), Committee on Payments and Market Infrastructures (CPMI) and International Organization of Securities Commissions (IOSCO) report on margin transparency. Proposal 6 covers a backward-looking metric on procyclicality. As currently specified, the observation window – the period over which the largest margin move is reported – is only one year in length. This means market participants will, for now, only have observations covering benign markets without much volatility. As a result, elevated procyclicality will not have been properly observed and meaningful information about past large margin moves that would be helpful to market participants’ liquidity planning will only be available after the next crisis and will not include shocks experienced in 2020 or 2022. In the paper, ISDA makes proposals about how this process could be improved.