ISDA and other industry associations have written a letter to FSB, BIS and IOSCO asking for a suspension of any initial margin (IM) requirement until its impact has been fully analysed. The Quantitative Impact Study accompanying the Basel Committee’s and IOSCO’s near-final proposals in February misstates the level of IM that would be required. The letter warns that IM requirements could cause procyclicality and push users to rely on imperfect hedges or dissuade them from hedging or from carrying out the underlying activity altogether. Some derivatives cannot not be cleared. Encouraging clearing houses to accept them would also pose a risk to financial stability. (Source: Re: Margin Requirements for Non-Centrally-Cleared Derivatives)