July 19, 2018
A new whitepaper has been posted on ISDA.org:
The final phases of the uncleared margin rules will occur on September 1 of 2019 and 2020, when a large number of additional counterparties will be brought into scope for initial margin (IM) requirements. The significant number of counterparties coming into scope in the final phases will create an untenable rush of demand on market resources across participants and service providers in a relatively short time period. This in turn will result in significant operational and technology builds that must be undertaken to meet the swell of demand.
In this paper, ISDA and the Securities Industry and Financial Markets Association (SIFMA) seek to highlight the significant challenges market participants will encounter during the final phases of IM implementation and identify the key tasks and resulting hurdles that must be overcome to ensure an orderly implementation that avoids disruption to the functioning of the derivatives market.