ISDA WGMR Implementation Initiative

Creating a New CSA under New York Law and English Law: ISDA and IHS Markit Tutorial Series

aosphere and ISDA webinar on new Collateral Provider and Collateral Taker Insolvency Opinions

ISDA Video Now Available: Preparing for the Variation Margin Rules

ISDA Amend December 1 Webcast Now Available: Launch of the Variation Margin Protocol 

In September 2013, the Working Group on Margin Requirements (WGMR), an initiative jointly run by the Basel Committee on Banking Supervision (BCBS) and the International Organization of Securities Commissions (IOSCO), issued the final margin policy framework for non-cleared, bilateral derivatives. Individual regulatory authorities across jurisdictions have since started to develop their own margin rules consistent with the final framework.

ISDA initiated a WGMR Implementation Program to facilitate the implementation of the margin rules across jurisdictions.

A key component of the WGMR Implementation Program is the Standard Initial Margin Model (SIMM)TM project, which is focused on developing a common initial margin (IM) methodology that can be used by market participants globally.  Unlike the calculation of variation margin, which is based on day-to-day valuation changes that are often directly observable, initial margin calculations very much depend on the choice of model and the assumptions used. Under the framework set by the WGMR, firms can use their own internal models to calculate initial margin, as long as they meet certain criteria and obtain regulatory approval. These models have the potential to differ significantly, raising the possibility that counterparties will arrive at a different initial margin figure for the same trade. The result would be a surge in the number of disputes – and no obvious way currently in place to quickly resolve them. The SIMM provides an open, transparent, standard methodology that will be available to all.

In addition to the SIMM workstream, several ISDA WGMR implementation workstreams were formed to address all areas necessary for broad market compliance with new rules for both IM and variation margin (VM), including portfolio integrity, collateral management process changes, data, dispute resolution, and new legal documentation to govern collateral and segregation relationships.  The ISDA WGMR Oversight Committee coordinates the work of all the above workstreams.


WGMR Margin & Collateral Processing/Portfolio Integrity   (J. Pucciarelli)

WGMR Data Sources  (T. Kruse/E. Hsu)

WGMR Legal & Documentation  (K. Darras)

ISDA SIMM Governance Forum  (T. Kruse)

DateTitle / DescriptionDocuments
December 1, 2016
ISDA Amend Webcast: Launch of the Variation Margin Protocol
ISDA Amend 2.0 includes a new protocol to enable market participants adhere to the variation margin requirements under various legal jurisdictions. Following on from our overview of the Self-Disclosure Letter, the next step requires participants to amend Credit Support Annexes (CSAs) to address regulatory compliance. This joint webcast with Markit helps market participants prepare for the upcoming uncleared margins deadline.
ISDA Amend 2.0 – Variation Modular Protocol-20161201 1451-1.mp4 ISDA Amend 2 0_webcast_Dec 01 2016 FINAL2 updated.pdf
November 28, 2016
Getting Ready for the March 1, 2017 Variation Margin Requirements: What Steps Do I Need to Take? (English language version)
A list of steps prepared by ISDA on how to get ready for the March 1 variation margin deadline.
ISDA Margin Fact sheet FINAL.pdf
November 15, 2016
ISDA Announces New Head of Non-cleared Margin Initiative
Press Release
WGMR new head press release FINAL.pdf
October 26, 2016
ISDA Amend Webcast: Are you prepared for the next wave of margin rules?
Jurisdictions around the world are implementing regulatory margin requirements for non-cleared derivative transactions. ISDA Amend 2.0 includes new functionality to allow market participants to exchange information to determine if their trading relationships are subject to margin requirements. This joint webcast with Markit helps market participants prepare for the upcoming regulatory deadlines.
ISDA Amend Webcast: Are you ready for the margin rules?
September 1, 2016
Margin for Non-cleared Derivatives: ISDA Initiatives
The introduction of new margin requirements for non-cleared derivatives will transform how firms use derivatives, and will require significant changes to infrastructure, processes, models and documentation. ISDA has been working on a number of initiatives to help firms meet the rules.
Margin for Non-cleared Derivatives ISDA initiatives.pdf
August 11, 2016
ISDA Amend Webcast: Are you ready for the margin rules?
ISDA Amend 2.0 includes new functionality to allow market participants to implement the new margining requirements for non-cleared derivatives, as well as the ability to inform counterparties about elections they have made under the ISDA Resolution Stay Jurisdictional Modular Protocol (ISDA JMP). This joint webcast with Markit helps market participants prepare for the upcoming regulatory deadlines.
ISDA Amend Webcast: Are you ready for the margin rules?
ISDA Amend 2 0_webcast_Aug 11 2016 (final).pdf
July 8, 2016
ISDA letter to BCBS/IOSCO requesting uniformity in time frame for margin requirements
On July 8, 2016, ISDA sent a letter to the Basel Committee on Banking Supervision and International Organization of Securities Commissions requesting that the phase-in of the derivatives margin requirements is reset so there is a uniform time frame for adopting the margin rules in all major financial jurisdictions.
ISDA-Letter-to-BCBS-IOSCO-Global-Harmonization-Due-to-EU-Delay (002).pdf
July 7, 2016
Important Notice to Market Participants re: Application of Margin Rules to Phase 1 groups
Re impact of the US rules on margin for uncleared swaps for funds that are consolidated on the financial statements of large financial groups.
Application of Margin Rules to Phase 1 Groups.pdf
May 3, 2016
ISDA letter to European Commission on Margin RTS
On April 29, 2016, ISDA submitted a letter to the European Commission on the Margin RTS drafted by the European Supervisory Authorities. The letter covers a range of issues, but does not cover variation margin settlement timing, which will be addressed in a separate letter.
ISDA - Margin RTS - Letter to EC 280416.pdf
April 22, 2016
ISDA letter to BCBS-IOSCO seeking relief regarding swaps in jurisdictions without final rules
On April 22, 2022 ISDA submitted a letter to BCBS-IOSCO seeking temporary relief from margin requirements, for swaps, which a Covered Entity enters into with a covered counterparty in a jurisdiction which has not yet finalized its margin rules.
ISDA - Margin Interpretation Issues - Letter to BCBS-IOSCO Asking for Re.pdf