Now that a couple of months have passed since Phase 6 of Uncleared Margin Rules (UMR) was implemented, it’s time to examine some of the lessons learned from this latest stage.
One lesson that stands out is how important it is to use time wisely. Finalizing CSAs (Credit Support Annexes) and ACAs (Account Control Agreements) took more time than expected as such a large number of firms came into scope, with additional delays on custodian accounts and counterparties signing documents. Threshold monitoring can help you avoid delays by giving you the ability to monitor REG IM (Regulatory Initial Margin) values from your broker, which allows for parties to finalize onboarding activities when they are still under the $50 million threshold. This is also a great cost-saver for relationships that may never breach the REG IM threshold or take years to do so.