A CFTC interim final rule to delay the implementation of "Phase Five" initial margin requirements for uncleared derivatives was published in the Federal Register. The rule is now effective and comments must be submitted by September 8, 2020.
As previously covered, the delay follows a recommendation from the Basel Committee on Banking Supervision-IOSCO. Under the interim final rule, the implementation will (i) be delayed from September 1, 2020 to September 1, 2021 and (ii) affect firms with an aggregate average notional amount of between $50 billion and $750 billion over the relevant measuring period.
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