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
August 18, 2014
ISDA letter to the ESAs on Proposed Margin Rules: Documentation Requirements
ISDA is concerned about the documentation that is required for parties to qualify for exemptions from the margin requirements under the Draft RTS on risk-mitigation techniques. This documentation is not required by Regulation (EU) No 648/2012 ("EMIR") and imposing such requirements would result in very significant administrative and operational burdens. In the letter, we set out proposed alternative language that could be used to permit exemptions without documentation requirements. This letter is a supplement to the letter we sent to the ESAs on July 14 commenting generally on the Draft RTS.
Aug 18 (2) - ISDA_Letter_re_EU_Margin_Documentation 18082014 final (3).pdf
August 17, 2014
ISDA letter to the ESAs on Proposed Margin Requirements: Analysis of Currency Mismatch Haircut
ISDA is concerned about the haircut for a currency mismatch that is proposed in the Consultation Paper on margin and has prepared the attached analysis and counter-proposal.
Aug 17 - EMIR_Margin_RTS_Response_-_FX_Haircut_Cover_Letter 17082014.pdf Aug 17 (2) - ISDA_-_EMIR_Margin_-_FX_Haircut_examples final 17082014.pdf
July 14, 2014
Consultation Paper regarding draft regulatory technical standards on risk-mitigation techniques for OTC-derivative contracts not cleared by a CCP
ISDA and SIFMA respond to the Consultation Paper on the Draft regulatory technical standards (the "Draft RTS") on risk-mitigation techniques for OTC-derivative contracts not cleared by a CCP under Art. 11(15) of Regulation (EU) No 648/2012 published by the European Securities and Markets Authority (ESMA), the European Banking Authority (EBA) and the European Insurance and the Occupational Pensions Authority (EIOPA, and together with ESMA and EBA, the ESAs) on April 14, 2014.
July 14 - ISDA-SIFMA Response.pdf
April 14, 2014
Consultation Paper: Draft regulatory technical standards
The European Supervisory Authorities (ESAs) have been mandated to develop common draft regulatory technical standards (RTS) that outline the concrete details of the regulatory framework which implements Article 11 of Regulation (EU) No 648/2012 (EMIR). EMIR, specifically, introduces a requirement to exchange a margin on non-centrally cleared OTC derivatives. As part of the process, this consultation paper seeks stakeholders’ views on the proposals.
April 14 - JC+CP+2014+03+(CP+on+risk+mitigation+for+OTC+derivatives).pdf
March 26, 2014
Standard Initial Margin Model for Non-Cleared Derivatives: White Paper and Appendix
A whitepaper discussing the SIMM for non-cleared derivatives was published by ISDA in December 2013. An appendix to the paper discussing risk factors and idiosyncratic risk was added in March 2014.
March 26 - SIMM for Non-Cleared Paper & Appendix.pdf
September 2, 2013
BIS / IOSCO Margin requirements for non-centrally cleared derivatives
This document presents the final policy framework that establishes minimum standards for margin requirements for non-centrally cleared derivatives as agreed by the BCBS and IOSCO. This final framework was developed in consultation with the Committee on Payment and Settlement Systems (CPSS) and the Committee on the Global Financial System (CGFS).
Sep 2 - bcbs261.pdf