On November 27th, the International Swaps and Derivatives Association published an analysis of initial margin ("IM") requirements for non-centrally cleared over-the-counter derivatives under current regulatory proposals. The IM analysis is based upon data submitted by member firms to the Basel Committee on Banking Supervision and the International Organization of Securities Commissions joint Working Group on Margining Requirements, as part of the Working Group's Quantitative Impact Study. The analysis highlights three significant industry concerns: the level of IM required under the BCBS-IOSCO proposal; the pro-cyclical increased amount of IM that would be required in stressed conditions; and the use of thresholds, which are designed to decrease IM requirements, but which will amplify the pro-cyclicality of the IM requirement during market stresses and add to systemic risk concerns. ISDA Press Release.