ISDA, SIFMA, the Global Financial Markets Association and SIFMA
AMG (collectively, the "associations") urged U.S. regulators to provide guidance on
implementing Basel Committee on Banking Supervision and IOSCO
("BCBS-IOSCO")
recommended exemptions from swaps margin requirements where the
amounts to be transferred are below relevant thresholds.
In a letter to the CFTC, the SEC and prudential regulators, the
associations requested assurance that swap dealers and their
counterparties would be exempt from Phase IV and V initial margin
requirements unless the bilateral initial margin amount exceeds $50
million. According to the associations, such an action would save
many Phase IV and V counterparties from a "massive
documentation and operation[al] burden."