In a pragmatic move, ISDA has recommended a delay and phase-in of initial margin requirements applicable to uncleared swaps.
Under the current timetable...proposed by BCBS/IOSCO in September 2013, new rules are expected to be finalized by local regulators in April 2015. Initial margin requirements will take effect for...those with notional exposure over US$3trn...in December 2015 and a phased approach will bring more...counterparties on board each year until...2019. According to the proposals, variation margin will apply to all counterparties with swaps exposures above the minimum threshold at the first 2015 implementation date. ISDA recommends that initial margin requirements take effect two years after the rules become final and variation margin requirements are phased in over the same period. [T]he industry’s recommendation would see the largest participants brought on board in 2017. Under a compressed phase-in, further groups would...then be added by lowering the threshold every two-to-three months until December 2019, when all relevant counterparties would become subject to the requirements.