EACT & US Coalition for Derivatives End-Users submit responses to the BIS-IOSCO Consultations on Margin Requirements for Non-centrally-cleared Derivatives

The EACT has, together with the US Coalition for Derivatives End-Users, submitted responses to the BIS-IOSCO Consultations on Margin Requirements for Non-centrally-cleared Derivatives. The responses highlight that non-financial end-users should be exempt from mandatory margining requirements for OTC derivative trades or only be required to post margin above a certain threshold. Introducing mandatory margining requirements would impose unnecessary cost and liquidity burdens to non-financial end-users, which could push some end-users to stop using derivatives which are however essential for corporates to be able to hedge commercial risk. The fact that non-financial end-users' derivative exposures pose little to no systemic risk should be taken into account when drafting the BIS-IOSCO recommendations. For the first consultation (July 2012), the joint submission can be viewed here  and the BIS-IOSCO consultation document can be found here. For the second consultation (February 2013), the joint submission can be viewed here and the BIS-IOSCO consultation document can be found here.