Derivatives end users are concerned about the impact of new margin requirements for non-cleared derivatives, with a large number unsure whether they will even have to comply with the rules, according to a survey published by the International Swaps and Derivatives Association, Inc., or ISDA.

The new proposed rules, which will require many derivatives users to post initial and variation margin on non-cleared derivatives transactions, are planned to be phased in from December 2015. But a third of survey respondents said they were unsure whether they would be subject to the rules. And of the 36% that knew they would have to comply, nearly two thirds (65%) said they were concerned or somewhat concerned about their ability to meet the requirements.

It’s easy to see why people are confused.  See our discussion of the proposed CFTC rule here and the proposed banking regulators’ rule here.  And those links do not include proposals from regulators in Europe and Japan.