On its response to the Basel Committee’s and IOSCO’s second consultation on margin requirements for non-centrally-cleared derivatives, IMA has focused on the group-basis approach to calculating exposure to derivatives. It says that where sub-funds are legally segregated from each other, as under the protected cell regimes, exposure to derivatives should be calculated at the level of the sub-fund. IMA also asks for inflation derivatives to be included in the same class as interest rate and currency derivatives, so that netting of exposures is possible across these types of derivatives. (Source: IMA Response on Margin for Non-Centrally-Cleared Derivates)