Key questions in the European Market Infrastructure Regulation (EMIR) include will there be universal initial margining, how will it be calculated, will thresholds be permitted, what will count as eligible collateral, will letters of credit be included and, if so, on what basis? These and many other issues remain unsettled. The International Organization of Securities Commissions (IOSCO) and the Basel Committee on Banking Supervision (BCBS) issued a first consultation in July 2012, following which, amid concerns about the liquidity impact of the margining proposals, they conducted a quantitative impact study (QIS) and revised their proposals. Eight principles on which these revised proposals will be based are now set out in a second BCBS/IOSCO consultative paper (the Paper) published on 15 February for comment by 15 March. This white paper discusses the main principles of these proposals and what they mean to those working in financial markets.
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