Financial counterparties and NFC+ entities are gradually being drawn into the scope of the EMIR requirement to post initial margin for non-cleared derivatives. Next month the EMIR initial margin requirements reach “Phase 3 entities” – those having more than EUR 1.5 trillion aggregate notional. Those with more than EUR 2.25tr – phases 1 and 2 – are already in scope, phase 4 (more than EUR 750bn) are covered from September 2019 and finally phase 5 (EUR 8bn+) fall in from September 2020. And who are these mega-players? Risk.net reported on Monday that Brevan Howard (a UK-based hedge fund) is expected to be the first, and so far only, buy side firm to qualify.