Are you coming into scope for the Uncleared Margin Rules?
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Acadia has a wide range of tools to suit every firm - having helped the majority of firms in scope for the Uncleared Margin Rules (UMR) since the first Phase came into effect in 2016. We have a team full of expert knowledge on UMR regulation and can help you understand what needs to be done.

Whether you need help with your AANA calculation, IM Model Validation, or monitoring your Initial Margin (IM) exposure – Acadia has the tools to assist you. 
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We can provide anything from finding out whether you are in scope and monitoring for threshold breaches to full calculation and exchange of Initial Margin. 
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Take advantage of our experience and let one of our team guide you in the right direction.

"Do NOT underestimate the time needed to complete. There is a huge amount of negotiation involved."
- Phase 5 Firms
BOOK A MEETING WITH OUR TEAM

Helpful Resources


IM Monitoring WhitepaperLearn more >

Further
ResourcesLearn more >

IM Validation in Europe WebinarLearn more >

AANA
Calculation GuideLearn more >

IM Monitoring
PodcastLearn more >

Unpacking EMIR RTS on Initial Margin Model ValidationLearn more >

GUIDELINES

2021-02-01

Identification of In-scope

Aggregate average notional amount of non-cleared Derivatives will inform UMR obligations.

February 2021

Identification of In-scope

All financial services firms will need to perform a complete analysis of their aggregate average notional amount (AANA) of non-cleared derivatives at the consolidated corporate group level. The results of this analysis will then need to be compared against the set levels defined by the Uncleared Margin Rules, to determine whether the firm lies in-scope for Phase 6 (deadline September 2021) of the incoming regulation.

2021-02-01
2019-01-01

2021-04-01

Counterparty Disclosure

Early disclosure is highly recommended.

April 2021

Counterparty Disclosure

Early disclosure is highly recommended to allow each firm to determine the impacted number of counterparty relationships. Internal leads across the Business, Legal, Documentation and Operations functions will need to be established, and serve as the firm’s key representative – this list should also be shared with ISDA & Acadia. Industry working groups hosted by ISDA & Acadia provide unique opportunities for these representatives to learn, share and collaborate towards the smoothest possible industry-wide adoption of Phase 6 UMR.

2021-04-01
2019-01-01

2021-07-01

Defining Approach

Selecting and communicating the best-fit approach for each organization.

July 2021

Defining Approach

Important decisions need to be made about how organizations will comply with the IM requirements. Firms will need to agree on custodians for posting IM, agree on thresholds and MTA with counterparties, agree on eligible collateral and define minimum internal standards for collateral schedule, decide on usage of Schedule or SIMM™ for IM methodology, and define an internal client priority for go-live efforts. If you decide to use the SIMM™ model, apply to ISDA for your license.

2021-07-01
2019-01-01

2021-10-31

IM Threshold Monitor

Set up a process to monitor the IM threshold (up to max of 50M at group level).

October 2021

IM Threshold Monitor

Define and execute the in house or vendor based solution for IM threshold monitor

2021-10-31
2019-01-01

2021-12-01

Calculation & Operational Set-up

Computing UMR margin and supporting daily operations will require firms to build or outsource new infrastructure.

December 2021

Calculation & Operational Set-up

Building on the planning and preparation completed thus far, firms will need to develop or outsource the infrastructure required to compute margin under UMR and operationally support the daily margining process. From preparing the regulatory IM calculator, integrating / preparing to integrate with best-practice industry platforms including Acadia’s IM Exposure Manager and ISDA’s Crowdsourcing Utility, developing backtesting / benchmarking routines on annual & quarterly basis along with internal monitoring, and then developing the necessary operational capabilities.

2021-12-01
2019-01-01

2022-01-01

Custodian Set-up

Bi-lateral connectivity required to the custodians selected in 'Defining Approach'.

January 2022

Custodian Set-up

Following on from the ‘Defining Approach’ step above and agreeing Custodians for posting IM, firms will need to establish bilateral connectivity to the selected institutions. With procedural and infrastructural implications, firms will need to complete all the necessary KYC checks required by each Custodian, establish segregation account(s), and test all connections to ensure resilience and effectiveness.

2022-01-01
2019-01-01

2022-02-01

Obtain Regulatory Model Approval

Firms require regulatory approval to use SIMM™ in their UMR compliance.

February 2022

Obtain Regulatory Model Approval

Regulatory approval is required for firms seeking to use SIMM™ as part of their UMR compliance – wherever applicable, firms will need to prepare the appropriate documentation and processes. This will require a combination of in-house and external resources to support the regulatory approval process, the model governance and validation process, and the drafting of all necessary policies and procedures.

2022-02-01
2019-01-01

2022-04-01

Negotiate/Execute Documentation & Go-live Testing

Ensuring complete contracts and a tested workflow are live for each counterparty pair.

April 2022

Negotiate/Execute Documentation & Go-live Testing

Bilateral Initial Margin CSA or collateral transfer agreement / security agreements, for each counterparty pair, will need to be in place before the Phase 6 go-live date – and tested on executions of bilateral IM CSA as well as trilateral with custodian account. Ensuring that all necessary relationships are live and ready for activation, ideally three months out from Phase 6 go-live, provides peace of mind and regulatory reassurance that all obligations have been met.

2022-04-01
2019-01-01

2022-09-01

Phase 6 UMR Go Live

Your UMR compliance journey has begun

September 2022

Phase 6 UMR Go Live

Your UMR compliance journey has begun

2022-09-01
2019-01-01

Start Planning

Request a meeting with one of our team to arrange an open discussion on how Acadia can help your UMR compliance project and what solutions best suit your firm.
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Acadia can provide:

  • AANA Calculation
  • Initial Margin Monitoring
  • Initial Margin Exposure Calculation & Reconciliation
  • Backtesting
  • Initial Margin Model Validation
  • Full suite for calculation and exchange of Initial Margin
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