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Jan 24, 2023

Lessons Learned from Uncleared Margin Rules Phase 6

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. 

Aug 30, 2022

Uncleared Margin Rules Phase 6: Final Preparations

Phase 6 of Uncleared Margin Rules is set to take effect within days, and we hosted an "SS&C Middle Office Series - UMR" podcast in which we discussed ways to confirm your readiness for compliance. The fast-approaching deadline doesn’t mean you can soon stop thinking about the changes, and it doesn’t mean you’re too late to take actions that will help your firm make the best decisions.

Jun 23, 2022

Uncleared Margin Rules Phase 6 is Coming: Are You Ready?

With Phase 6 of Uncleared Margin Rules set to go live September 1, 2022, managers with Average Aggregate Notional Amounts (AANA) in excess of 8 billion are preparing. AANA is calculated slightly differently depending on the jurisdiction. For US CFTC (Commodity Futures Trading Commission) and EMIR (European Market Infrastructure Regulation) regulators, AANA calculation uses the average month-end value from March, April and May 2022. US Prudential Regulators (USPR) use a daily AANA calculation for each business day from June, July and August 2021. If entities in different jurisdictions are subsidiaries of each other, then AANA must be calculated across entities.

Dec 7, 2020

Understanding and Adhering to Un-cleared Margin Rules (UMR)

Is your firm in scope for UMR? SS&C’s whitepaper, OTC Derivatives Workflow for Un-cleared Margin Rules in the EU and US, provides a simple flow chart to help you determine whether your firm is in scope, and for which phase.

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