By John Pucciarelli – Head of Industry & Regulatory Strategy, Acadia
The industry has been waiting with bated breath for the past two years to discover the European regulators decision on how firms that are in scope for uncleared margin rules (UMR) are required to validate their initial margin (IM) models.
On 4th November 2021, the European Banking Authority issued the Draft Regulatory Technical Standards
on Initial Margin Model Validation (IMMV). Within the consultation document, they clarify the proposed requirements for IM model validation (ISDA SIMMTM) which we will aim to distil specifically for Phase five and six firms. Please note: The RTS is in draft status, with the comment period closing on 4 February 2022. The interpretation of the draft RTS is Acadia’s opinion and should not be treated as legal advice.
1 These RTS propose a transitional provision (Article 30), which establishes that counterparties already implementing an IM model and applying for the supervisory validation in due time (one month from the entry into application of the provisions in these RTS) would be allowed to keep using the IM model. During the transitional phase, once the counterparties have applied for the supervisory validation, the competent authorities will have up to two years to raise any issues on the model implementation, based on the requirements in the regulatory framework
About John Pucciarelli
John Pucciarelli is Head of Industry & Regulatory Strategy at Acadia. John is leading Acadia’s outreach to IM phase 5 & 6 firms building on his knowledge and experience as well as overseeing Acadia’s interactions with global regulators and industry associations. John was previously with The International Swaps and DerivativesAssociation (ISDA) as Director of Market Infrastructure and Technology. John led margin and collateralInitiatives for the ISDA membership overseeing the implementation of the initial phases of the non-cleared margin rules from an operations and business perspective. Prior to joining ISDA, John was with AQR CapitalManagement where he oversaw their middle office operational functions. Earlier on in his career, John worked for UBS Investment Bank where he supervised their US Equity Prime Brokerage Operations team.
For more information please visit us at acadia.inc Or email us at info@acadia.inc
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By John Pucciarelli – Head of Industry & Regulatory Strategy, Acadia
The industry has been waiting with bated breath for the past two years to discover the European regulators decision on how firms that are in scope for uncleared margin rules (UMR) are required to validate their initial margin (IM) models.
On 4th November 2021, the European Banking Authority issued the Draft Regulatory Technical Standards
on Initial Margin Model Validation (IMMV). Within the consultation document, they clarify the proposed requirements for IM model validation (ISDA SIMMTM) which we will aim to distil specifically for Phase five and six firms. Please note: The RTS is in draft status, with the comment period closing on 4 February 2022. The interpretation of the draft RTS is Acadia’s opinion and should not be treated as legal advice.
1 These RTS propose a transitional provision (Article 30), which establishes that counterparties already implementing an IM model and applying for the supervisory validation in due time (one month from the entry into application of the provisions in these RTS) would be allowed to keep using the IM model. During the transitional phase, once the counterparties have applied for the supervisory validation, the competent authorities will have up to two years to raise any issues on the model implementation, based on the requirements in the regulatory framework
About John Pucciarelli
John Pucciarelli is Head of Industry & Regulatory Strategy at Acadia. John is leading Acadia’s outreach to IM phase 5 & 6 firms building on his knowledge and experience as well as overseeing Acadia’s interactions with global regulators and industry associations. John was previously with The International Swaps and DerivativesAssociation (ISDA) as Director of Market Infrastructure and Technology. John led margin and collateralInitiatives for the ISDA membership overseeing the implementation of the initial phases of the non-cleared margin rules from an operations and business perspective. Prior to joining ISDA, John was with AQR CapitalManagement where he oversaw their middle office operational functions. Earlier on in his career, John worked for UBS Investment Bank where he supervised their US Equity Prime Brokerage Operations team.
For more information please visit us at acadia.inc Or email us at info@acadia.inc
By John Pucciarelli – Head of Industry & Regulatory Strategy, Acadia
The industry has been waiting with bated breath for the past two years to discover the European regulators decision on how firms that are in scope for uncleared margin rules (UMR) are required to validate their initial margin (IM) models.
On 4th November 2021, the European Banking Authority issued the Draft Regulatory Technical Standards
on Initial Margin Model Validation (IMMV). Within the consultation document, they clarify the proposed requirements for IM model validation (ISDA SIMMTM) which we will aim to distil specifically for Phase five and six firms. Please note: The RTS is in draft status, with the comment period closing on 4 February 2022. The interpretation of the draft RTS is Acadia’s opinion and should not be treated as legal advice.
1 These RTS propose a transitional provision (Article 30), which establishes that counterparties already implementing an IM model and applying for the supervisory validation in due time (one month from the entry into application of the provisions in these RTS) would be allowed to keep using the IM model. During the transitional phase, once the counterparties have applied for the supervisory validation, the competent authorities will have up to two years to raise any issues on the model implementation, based on the requirements in the regulatory framework
About John Pucciarelli
John Pucciarelli is Head of Industry & Regulatory Strategy at Acadia. John is leading Acadia’s outreach to IM phase 5 & 6 firms building on his knowledge and experience as well as overseeing Acadia’s interactions with global regulators and industry associations. John was previously with The International Swaps and DerivativesAssociation (ISDA) as Director of Market Infrastructure and Technology. John led margin and collateralInitiatives for the ISDA membership overseeing the implementation of the initial phases of the non-cleared margin rules from an operations and business perspective. Prior to joining ISDA, John was with AQR CapitalManagement where he oversaw their middle office operational functions. Earlier on in his career, John worked for UBS Investment Bank where he supervised their US Equity Prime Brokerage Operations team.
For more information please visit us at acadia.inc Or email us at info@acadia.inc
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