Reg IM – Is Wave 4 playing second fiddle to Brexit?

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 recent article on the regulatory requirements for Initial Margin (“IM”) segregation we posed the question, “Are you Ready?” There is a view held in some quarters that preparation work in readiness for Wave 4 can be done from April onwards after Brexit work is completed, notwithstanding potential delays because of current uncertainty over the terms of a deal / no-deal exit.

There are indeed 5 months between April and September to sort out any preparation needed for Reg IM.  However, consider these two points when determining the priority given to Reg IM work:

  1. The lead-time on actions is significant and will require engagement and coordination with multiple parties.
  2. Sources of good quality advice are not so obvious:
    • Dealers and brokers are not experienced in setting up Sell-to-Buy side arrangements (Waves 1-3 were 98% Sell-to-Sell and full Tri-Party arrangements);
    • Buy-side custodians are new to Reg IM themselves;
    • Most consultancies have no experience of assisting firms in setting up Sell-to-Buy side arrangements; and
    • Holley Holland has almost unique experience gained in preparing buy-side clients for Waves 3 and 4.

Whether you are scheduled for Wave 4 or 5, but especially for Wave 4, working smart is your best option:

  • Work through our checklists.
  • Reach out for advice – Holley Holland can tailor an engagement exactly to your needs, ranging from light touch independent advice through to full implementation management and support.

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