On October 25, MFA submitted the attached letter to the Working Group on Margining Requirements (WGMR) of the Basel Committee on Banking Supervision and IOSCO. This letter provides constructive and targeted recommendations to facilitate the smooth and efficient implementation of minimum initial margin (IM) requirements for non-cleared derivatives. The final phases of these IM requirements will come into effect on September 1, 2019 (Phase 4) and September 1, 2020 (Phase 5).
