On March 18, the Basel Committee on Banking Supervision and the International Organization of Securities Commissions (IOSCO) published a “final” policy framework that establishes minimum global standards for margin requirements for non-centrally cleared derivatives. Relative to the initial framework published in September of 2013 (see the Corporate & Weekly Financial Digest article from September 13, 2013, here), the revisions delay the beginning of the phase-in period for collecting and posting initial margin on non-centrally cleared trades from December 1, 2015 to September 1, 2016. The full phase-in schedule has been adjusted to reflect this nine-month delay. The revisions also institute a six-month phase-in of the requirement to exchange variation margin, beginning September 1, 2016.

The CFTC, SEC and banking regulators responsible for promulgating margin regulations for US swap market participants are expected to adopt the same phase-in schedule for their own rules in order to ensure consistent implementation across products, jurisdictions and market participants.

The revised margin framework can be found here.

A table showing the new phase-in dates can be found here.