Starting on September 1, 2018, so-called Phase 3 firms—which include mid-tier regional banks, asset managers and fund administrators—will have to post initial margin for all non-cleared derivatives transactions to comply with International Swaps and Derivatives Association (ISDA) guidelines. Phase 1 and 2 firms are already adhering to it as of September 2016 and ’17, respectively.
The ISDA Standard Initial Margin Model (SIMM) is designed to create a standard methodology for calculating initial
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