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ARTICLE · 13 SEPTEMBER 2016

ISDA CEO Urges More Realistic Timeline For Swap Margin Requirement Implementation

Hogan Lovells Cadwalader
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ISDA CEO Scott O'Malia asserted that the implementation of non-cleared margin requirements on September 1, 2016 "went relatively smoothly given the scale of the change and the time given to the industry [to] prepare for it."

United StatesFinance and Banking

ISDA CEO Scott O'Malia asserted that the implementation of non-cleared margin requirements on September 1, 2016 "went relatively smoothly given the scale of the change and the time given to the industry [to] prepare for it."

In a recent blog post, Mr. O'Malia noted that preparations were complicated "by news that European regulators wouldn't have their rules ready in time for a September launch – with Australia, Hong Kong, India and Singapore subsequently following Europe's decision to defer the start date until next year." Mr. O'Malia claimed that this delay created "new cross-border and compliance headaches."

Mr. O'Malia stated:

Adapting or agreeing [to] new collateral agreements and setting up custody accounts for every in-scope counterparty relationship cannot be completed in a matter of weeks. While only 20 or so entities were caught by the first-phase implementation in the U.S., Japan and Canada, it required negotiation or revision of hundreds, if not

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