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With the rush earlier this year to fix legacy CSAs, the regulatory "forbearance" (which is generally assumed to last until 1 September to coincide with the deadline for phase 2 IM) and now MiFID II looming on the horizon, you might be forgiven if you have overlooked the requirements of the EMIR margin rules to have documented risk management procedures addressing how you have implemented the new rules.
The date for compliance with this aspect of the margin rules is 1 March 2017 but, with the industry assumed "deferral" to 1 September 2017 for having compliant CSAs, it follows that the date for having these policies and procedure in place must also be 1 September.
In order to help clients achieve compliance we have developed a cost-effective and comprehensive solution comprising a template document which captures all the risk management policy and procedure requirements imposed by the margin rules. It explains the requirements to have the policies and procedures in place and provides suggested policies and procedures based upon our knowledge and experience.
Although you (or your clients) may not be subject to the rules for the exchange of IM at this point, we have also addressed the IM requirements in order to future-proof the document and so that users can demonstrate an understanding of the scope of those rules.
Other than in the technical detail of any Initial Margin (IM) model our template document provides a complete solution to this aspect of the rules with limited editing.
We have developed separate versions for banks / brokers and asset managers as the requirements and application of the rules to each is quite different. Each document is over 30 pages in length and sample pages can be viewed using these links: banks and brokers and asset managers.
The cost of the standard document is GBP 3,500. For a small additional fee we are also able to tailor it to your specific requirements, extend the document to cover all EMIR legal and documentation requirements (not just the margin rules) and provide an update service.
Should you wish to enquire about this product, please get in touch with your usual Fieldfisher contact.