Reg IM – Are You Ready?

Matt Price & Shaun Sheppard

Shaun is a former co-chair of the iSDA Collateral Committee and has significant Collateral Management experience with both the buy-side and the sell-side organizations.

In our previous articles on the regulatory requirements for Initial Margin (“IM”) segregation we highlighted some of the challenges faced by market participants in developing compliant solutions and shared our 10 Point Readiness Health Check.

As Wave 4 looms large in 2019 now is the time for buy-side organisations to ensure that the following key questions are answered:

  1. Have you chosen you calculation method – SIMM or GRID?
  2. Do you or your collateral manager have an approved calculator?
  3. Have you chosen your custody model – bilateral, tri-party or hybrid?
  4. Does your custodian have an approved, compliant account?
  5. Do you know the approval route for custody account approval?

If the answer to any of the above questions isn’t clear then you might need expert advice.  There is a limited pool of industry expertise in implementing bilateral and hybrid custody models, which will be the right solutions for the majority of buy-side firms.  We have unique experience in helping buy-side organisations with each of these models to prepare for Wave 3 compliance could help you to:

  • Gain insight and analysis from an expert provider
  • Select a solution that is both effective and proportionate for your business
  • Negotiate IM agreements with your dealers from an informed position
  • Get ahead of the decision-making curve so you have enough time to do the heavy lifting (e.g. agreements and documentation) before implementation date
  • Avoid unnecessary major programme costs with large projects staffed with content-light change managers.

Timely engagement will help you to unpick the complexity of solutions available to you whilst reducing dependencies on the limited pool of expertise available within the industry.

For more information or to discuss any of the matters raised in this or our previous articles, please contact Matt Price at and Shaun Sheppard at