The Basel Committee on Banking Supervision and the International Organization of Securities Commissions delayed by nine months the initial implementation dates for the mandatory posting of initial and variation margin for uncleared swaps by covered derivatives users. The phase-in period for exchanging initial and variation margin on uncleared swaps will now commence on September 1, 2016 (instead of December 1, 2015) for the largest derivatives users. These are corporate groups whose aggregate month-end average notional amount of non-centrally cleared derivatives exceeds 3 trillion euro. The phase-in period for exchanging initial margin will continue for successively smaller covered entities through September 1, 2020 (instead of December 1, 2019). Smaller uncleared derivatives users will also be required to exchange variation margin commencing March 1, 2017 (instead of beginning December 1, 2015). Five US prudential regulators, including the Board of Governors of the Federal Reserve System, and the Commodity Futures Trading Commission previously proposed initial and variation margin requirements for uncleared swaps that incorporated the prior Basel Committee and IOSCO implementation schedules. (Click here for the article, “FRB and Four Other Federal Agencies Propose Minimum Margin Rules for Uncleared Swaps” in the September 1 to 5 and 8, 2014 edition of Bridging the Week, and here for the article, “CFTC Proposes Margin Rules for Uncleared Swaps and Approves Special Treatment for Operations-Related Swaps With Certain Government-Owned Natural Gas and Electric Utilities” in the September 15 to 19 and 22, 2014 edition of Bridging the Week for more details.) The International Swaps and Derivatives Association applauded the delay in the roll-out of uncleared swaps margin requirements. According to ISDA, "[f]irms have been working hard to prepare for the rules, but the changes would have been all but impossible to complete by the original December 2015 effective date, particularly as final rules have not yet been published by US, European and Japanese authorities."