ISDA, SIFMA, the American Bankers Association, the Global
Foreign Exchange Division of the Global Financial Markets
Association, and the Institute of International Bankers
(collectively, the "associations") offered recommendations to regulators to
mitigate potential negative impacts as initial margin requirements
for uncleared derivatives are expanded to capture buy-side market
participants.
Based on a recent survey performed by ISDA, it is expected that
the expansion of initial margin ("IM") requirements
scheduled to take place in September 2020 (referred to as
"Phase 5") will result in approximately 1,100 new
in-scope counterparties and 9,500 new counterparty relationships
being subject to regulatory IM. The survey further found that
between 26-45 percent of counterparties and 69-78 percent of
relationships brought in scope in Phase 5 are unlikely to require
exchange of IM at all (though the trading relationships will be
subject to the rules as a whole), as they
