Industry advocacy

On March 5, 2019, the Basel Committee on Banking Supervision and the International Organization of Securities Commissions (BCBS/IOSCO) issued guidance (the “BCBS/IOSCO Repapering Guidance”) related to the framework for margin requirements for non-centrally cleared derivatives noting that UMR does not specify documentation, custodial or operational requirements if the bilateral initial margin amount (“Reg IM”) does not exceed the UMR’s €50 million (or relevant currency equivalent) initial margin threshold. The BCBS/IOSCO Repapering Guidance has subsequently been adopted by national competent regulators, including those to which UBS is subject to. Although this guidance does not require counterparty pairings to complete legal documentation if Reg IM is below the regulatory prescribed threshold, a minimum set of attributes will need to be agreed to ensure a robust monitoring process is in place. Please use the "Contact Us" link to find out more about our monitoring process.

Final Phase Extension & AANA Adjustments.

On July 23, 2019 BCBS/IOSCO issued a statement revising the final implementation phase timeline. In addition, on April 03, 2020 BCBS/IOSCO an­nounced an extension of Phase 5 to September 01, 2021 and Phase 6 to September 01, 2022 in response to the impact of COVID-19. The corresponding AANA Calculation Periods have also been amended in line with the new dates. Phase 6 is the final imple­mentation phase, September 1, 2022 for entities with an AANA greater than €8 billion (or equivalent currency).

We encourage our Phase 6 clients to continue to engage with us to address papering requirements as Custodians have indicated early completion deadlines for documentation and collateral eligibility schedules. For clients that wish to pursue a monitoring arrangement, we also encourage you to Contact Us to discuss monitoring terms.