ISDA identified differences in the jurisdictional
implementations of margin requirements for non-cleared derivatives
that may have caused market fragmentation. ISDA considered
regulations in the following jurisdictions: the United States, the
European Union, the United Kingdom, Japan, Singapore, Hong Kong,
Australia, Switzerland and Canada.
In its paper, ISDA urged national regulators to prioritize
harmonizing margin requirements to avoid further market
fragmentation. According to ISDA, the major issues that regulators
must address include:
- inconsistent initial margin
("IM") collateral eligibility requirements;
- different IM settlement
timeframes;
- varying IM treatment for
inter-affiliate transactions;