The Basel Committee on Banking Supervision and IOSCO
("BCBS-IOSCO") issued a statement on the implementation of
derivatives margin requirements related to (i) benchmark reforms
and (ii) initial margin thresholds.
In the statement, BCBS-IOSCO indicates that amendments to
"legacy" derivatives contracts "solely for the
purpose of addressing interest rate benchmark reforms" do not
bring trades into scope for relevant margin requirements. However,
BCBS-IOSCO cautions that positions may be different under relevant
implementing laws.
In the statement, BCBS-IOSCO also addresses the 2019-2020 phased
implementation of initial margin requirements. In particular, they
take the view that the BCBS-IOSCO margin framework (last updated in
March 2015) does not impose "documentation, custodial or
operational requirements" where the amount of margin to be
posted remains below the €50 million threshold, but expects
firms to "act diligently" when exposures approach the
threshold, in
