uncleared margin reform - building a better working … · 2016-02-11 · review key data...
TRANSCRIPT
Uncleared margin reform Get ready — it’s coming soon
EY | Assurance | Tax | Transactions | Advisory About EY EY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working world for our people, for our clients and for our communities. EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. For more information about our organization, please visit ey.com. Ernst & Young LLP is a client-serving member firm of Ernst & Young Global Limited operating in the US. EY is a leader in serving the global financial services marketplace Nearly 43,000 EY financial services professionals around the world provide integrated assurance, tax, transaction and advisory services to our asset management, banking, capital markets and insurance clients. In the Americas, EY is the only public accounting organization with a separate business unit dedicated to the financial services marketplace. Created in 2000, the Americas Financial Services Organization today includes more than 6,900 professionals at member firms in over 50 locations throughout the US, the Caribbean and Latin America. EY professionals in our financial services practices worldwide align with key global industry groups, including EY’s Global Wealth & Asset Management Center, Global Banking & Capital Markets Center, Global Insurance Center and Global Private Equity Center, which act as hubs for sharing industry-focused knowledge on current and emerging trends and regulations in order to help our clients address key issues. Our practitioners span many disciplines and provide a well-rounded understanding of business issues and challenges, as well as integrated services to our clients. With a global presence and industry-focused advice, EY’s financial services professionals provide high-quality assurance, tax, transaction and advisory services, including operations, process improvement, risk and technology, to financial services companies worldwide. © 2016 All Rights Reserved. 1601-1807951 Score no. 1030 ED None This material has been prepared for general informational purposes only and is not intended to be relied upon as accounting, tax or other professional advice. Please refer to your advisors for specific advice. ey.com
Contacts Roy Choudhury Principal Office: +1 212 773 9299 [email protected]
Janina Polo Senior Manager Office: +1 212 773 2486 [email protected]
Prakash Rao Executive Director Office: +1 212 773 2188 [email protected]
John Boyle Senior Manager Office: +1 212 773 5412 [email protected]
Setu Pandya Senior Manager Office: +1 212 773 2437 [email protected]
The complexity of the workflow enhancements and the required technology build will require an average 22 months to deliver tactical and strategic solutions. Use the table below to check if you are ready!
New paradigm for uncleared derivatives in September 2016, the uncleared derivatives market will begin going through wide-ranging changes, such as the universal exchange of variation margin (VM) and two-way initial margin (IM), restriction of eligible forms of collateral, segregation for initial margin and new documentation requirements to govern collateral relationships.
While many impacted organizations have mobilized internal and industry-wide programs to address these regulations, much uncertainty remains as to whether market participants and their counterparties will be adequately prepared for the economic and operational impacts of the margin regulations and their nuances across jurisdictions.
As the leading professional services firm in this space, we offer cross-functional solutions to help our clients prepare, implement and demonstrate compliance with the uncleared margin regulations.
Global regulatory principles • Requires mandatory exchange of VM
• Requires universal two-way exchange of IM to be calculated using a risk-based model or standardized table
• Restricts eligible forms of collateral to highly liquid assets and prescribes methods to derive related haircuts
• Requires that collateral posted for IM is segregated and prohibits rehypothecation
• Defines specific CSA documentation to govern new collateral relationships
• Prescribes a compliance phase-in based on aggregate gross notional amounts beginning 1 September 2016
Key industry challenges • Implementation of global regulations has posed significant challenges to systems,
workflows and procedures for buy-side and sell-side institutions. Reliance on cross-border will be necessary due to inconsistencies and lack of harmonization across jurisdictions.
• Costs and process fragmentation associated with operating separate clearing platforms for listed and OTC derivatives, including different platforms for the US and Europe.
• The time and cross-functional coordination required to build, test and deploy new regulatory-compliant margin models, including integration with up and downstream processes.
• Industry-wide adoption of a regulatory approved risk-based initial margin model for uncleared swaps.
• The ability to produce simulations of margin calls/pre-trade initial margin estimates and cost of margining to assist the front office in pricing of trades is limited.
• Market participants will be required to execute regulatory compliant CSAs and ACAs as early as September 2016, for applicable uncleared swaps. The industry will rely on automated solutions to reduce lengthy bilateral negations.
• Legal agreements are often not integrated; they are stored independently of the margin management system. Inaccurate, insufficient and untimely information is fed down from front-office systems.
• Segregation requirements are expected to produce a surge in the number of counterparty accounts while adding greater complexity to existing segregation models.
• Anticipated massive increase in demand for high-quality cash and non-cash collateral. Many financial institutions lack a holistic and fully transparent view of their pools of eligible collateral or are unable to efficiently mobilize collateral to allocate it against specific exposures.
• Increase in margin call volumes as a result of the regulatory changes, clearing fragmentation, regional offerings and varying legal agreement structures will create scalability issues and promote the need for STP. Firms will also be required to fund larger cash balances to meet expected margin calls.
• Significant need for system integration and data infrastructure overhaul to support funding and operations processes, with many institutions already developing industry-based or proprietary solutions.
Global compliance date and threshold
1 Sep 2016 1 Sep 2017 Sep 1, 2018 1 Sep 2019 1 Sep 2020 1 Mar 2017
Initial margin starting 1 September 2016 — 1 September 2020
Variation margin — 1 September 2016 and 1 March 2017
Exceeds Exceeds
BCBS-IOSCO €3t
US $3.0t
EU €3.0t
Japan: ¥420t
Exceeds
Exceeds
BCBS-IOSCO
€3.0t
US $3.0t
EU €3.0t
Japan: TBD
All covered entities
Exceeds
Exceeds
BCBS-IOSCO €2.25t
US $2.25t
EU €2.25t
Japan: ¥315T
BCBS-IOSCO €1.5t
US $1.5t
EU €1.5t
Japan: ¥210t
BCBS-IOSCO €0.75t
US $0.75t
EU €0.75t
Japan: ¥105t
BCBS-IOSCO €8b
US $8b
EU €8b
Japan: ¥1.1t
Rule comparison across major jurisdictions
Topic Similarities Differences
Covered transactions Physically settled FX forwards and swaps are exempt from IM
[JP] Commodities not included in draft regulations [US] FX forwards and swaps exempt from VM [US] Exclusions apply (e.g., equity options) based on regulatory definition of swap [US] No exemptions for interaffiliate transactions
Covered entities Sovereigns, development banks, and nonfinancial end users are exempt
[N/A] No major differences among jurisdictions
IM model: margin period Ten-day margin period of risk (MPoR)
[EU] MPoR may be larger than 10 days due to concentration risk [US] MPoR may be less than 10 days if maturity of trade is less than 10 days [JP] IM model draft regulations not issued
IM model: netting Netting is not permitted across four broad categories of interest rates/FX, credit, equity and commodity
[EU] Further restrictions on netting via introduction of an “other” category [JP] IM model draft regulations not issued
IM model: historical period Equally weighted observations for no more than five years incorporating a period of financial stress
[EU] No less than three years with a minimum of 25% stress [US] No less than one year of data without [JP] IM model draft regulations not issued
IM model: calibration At least annual calibration [US] At least monthly calibration [JP] IM model draft regulations not issued
VM calculation At least daily calculation [N/A] No differences among jurisdictions
VM collection At least daily collection [EU] Collection permitted within three business days
Eligible collateral 1. Cash for VM in the settlement currency of swap
2. Cash and securities for IM subject to haircuts, including currency mismatch haircut
[US] VM also permitted in USD, not subject to a currency mismatch haircut [EU, JP] Cash or securities for VM subject to haircuts, including currency mismatch [EU] Concentration limits on types of collateral for systemically important institutions (over EUR 1b collected collateral)
Segregation IM segregation at a third party without rehypothecation
[EU, JP] IM may also be segregated through other legally effective means
Documentation Netting and margining to be legally documented
[EU] At least annual legal review of netting enforceability [JP] No explicit documentation requirements in draft regulations
Near-term areas of focus checklist
Define requirements and develop road map for margin call workflow
Confirm mechanism to flag positions — out-of scope, in-scope and exempt
Review key data attributes required to support regulatory IM and VM processing
Define data elements and feeds to third party for IM reconciliation
Confirm clients that will require legal agreement re-papering based on expected phase-in schedules
Conduct client outreach, education sessions and issue client notifications
Select and implement IM calculation approaches; internal models, external models, standard approach
Develop data mappings and interpolations to support IM calculations
Confirm use of credit assessment — internal, external or combined (only for EU)
Confirm approach for application of the 8% cross-currency haircut for IM (only for EU)
Develop and implement backtesting of IM models
Conduct IM model validation on the conceptual soundness of the IM model(s)
Develop dispute and escalation protocols
Develop client documentation and re-prepare related agreements
Select calculation approach — external model, internal model, standard schedule or combination
Internal control structure enablement
Global program management framework
Margin methodologies/ analytics
Current to future state assessment
Margin/ collateral redesign and implementation
Regulatory readiness package
Reference data management
EY offerings
The complexity of the workflow enhancements and the required technology build will require an average 22 months to deliver tactical and strategic solutions. Use the table below to check if you are ready!
New paradigm for uncleared derivatives in September 2016, the uncleared derivatives market will begin going through wide-ranging changes, such as the universal exchange of variation margin (VM) and two-way initial margin (IM), restriction of eligible forms of collateral, segregation for initial margin and new documentation requirements to govern collateral relationships.
While many impacted organizations have mobilized internal and industry-wide programs to address these regulations, much uncertainty remains as to whether market participants and their counterparties will be adequately prepared for the economic and operational impacts of the margin regulations and their nuances across jurisdictions.
As the leading professional services firm in this space, we offer cross-functional solutions to help our clients prepare, implement and demonstrate compliance with the uncleared margin regulations.
Global regulatory principles • Requires mandatory exchange of VM
• Requires universal two-way exchange of IM to be calculated using a risk-based model or standardized table
• Restricts eligible forms of collateral to highly liquid assets and prescribes methods to derive related haircuts
• Requires that collateral posted for IM is segregated and prohibits rehypothecation
• Defines specific CSA documentation to govern new collateral relationships
• Prescribes a compliance phase-in based on aggregate gross notional amounts beginning 1 September 2016
Key industry challenges • Implementation of global regulations has posed significant challenges to systems,
workflows and procedures for buy-side and sell-side institutions. Reliance on cross-border will be necessary due to inconsistencies and lack of harmonization across jurisdictions.
• Costs and process fragmentation associated with operating separate clearing platforms for listed and OTC derivatives, including different platforms for the US and Europe.
• The time and cross-functional coordination required to build, test and deploy new regulatory-compliant margin models, including integration with up and downstream processes.
• Industry-wide adoption of a regulatory approved risk-based initial margin model for uncleared swaps.
• The ability to produce simulations of margin calls/pre-trade initial margin estimates and cost of margining to assist the front office in pricing of trades is limited.
• Market participants will be required to execute regulatory compliant CSAs and ACAs as early as September 2016, for applicable uncleared swaps. The industry will rely on automated solutions to reduce lengthy bilateral negations.
• Legal agreements are often not integrated; they are stored independently of the margin management system. Inaccurate, insufficient and untimely information is fed down from front-office systems.
• Segregation requirements are expected to produce a surge in the number of counterparty accounts while adding greater complexity to existing segregation models.
• Anticipated massive increase in demand for high-quality cash and non-cash collateral. Many financial institutions lack a holistic and fully transparent view of their pools of eligible collateral or are unable to efficiently mobilize collateral to allocate it against specific exposures.
• Increase in margin call volumes as a result of the regulatory changes, clearing fragmentation, regional offerings and varying legal agreement structures will create scalability issues and promote the need for STP. Firms will also be required to fund larger cash balances to meet expected margin calls.
• Significant need for system integration and data infrastructure overhaul to support funding and operations processes, with many institutions already developing industry-based or proprietary solutions.
Global compliance date and threshold
1 Sep 2016 1 Sep 2017 Sep 1, 2018 1 Sep 2019 1 Sep 2020 1 Mar 2017
Initial margin starting 1 September 2016 — 1 September 2020
Variation margin — 1 September 2016 and 1 March 2017
Exceeds Exceeds
BCBS-IOSCO €3t
US $3.0t
EU €3.0t
Japan: ¥420t
Exceeds
Exceeds
BCBS-IOSCO
€3.0t
US $3.0t
EU €3.0t
Japan: TBD
All covered entities
Exceeds
Exceeds
BCBS-IOSCO €2.25t
US $2.25t
EU €2.25t
Japan: ¥315T
BCBS-IOSCO €1.5t
US $1.5t
EU €1.5t
Japan: ¥210t
BCBS-IOSCO €0.75t
US $0.75t
EU €0.75t
Japan: ¥105t
BCBS-IOSCO €8b
US $8b
EU €8b
Japan: ¥1.1t
Rule comparison across major jurisdictions
Topic Similarities Differences
Covered transactions Physically settled FX forwards and swaps are exempt from IM
[JP] Commodities not included in draft regulations [US] FX forwards and swaps exempt from VM [US] Exclusions apply (e.g., equity options) based on regulatory definition of swap [US] No exemptions for interaffiliate transactions
Covered entities Sovereigns, development banks, and nonfinancial end users are exempt
[N/A] No major differences among jurisdictions
IM model: margin period Ten-day margin period of risk (MPoR)
[EU] MPoR may be larger than 10 days due to concentration risk [US] MPoR may be less than 10 days if maturity of trade is less than 10 days [JP] IM model draft regulations not issued
IM model: netting Netting is not permitted across four broad categories of interest rates/FX, credit, equity and commodity
[EU] Further restrictions on netting via introduction of an “other” category [JP] IM model draft regulations not issued
IM model: historical period Equally weighted observations for no more than five years incorporating a period of financial stress
[EU] No less than three years with a minimum of 25% stress [US] No less than one year of data without [JP] IM model draft regulations not issued
IM model: calibration At least annual calibration [US] At least monthly calibration [JP] IM model draft regulations not issued
VM calculation At least daily calculation [N/A] No differences among jurisdictions
VM collection At least daily collection [EU] Collection permitted within three business days
Eligible collateral 1. Cash for VM in the settlement currency of swap
2. Cash and securities for IM subject to haircuts, including currency mismatch haircut
[US] VM also permitted in USD, not subject to a currency mismatch haircut [EU, JP] Cash or securities for VM subject to haircuts, including currency mismatch [EU] Concentration limits on types of collateral for systemically important institutions (over EUR 1b collected collateral)
Segregation IM segregation at a third party without rehypothecation
[EU, JP] IM may also be segregated through other legally effective means
Documentation Netting and margining to be legally documented
[EU] At least annual legal review of netting enforceability [JP] No explicit documentation requirements in draft regulations
Near-term areas of focus checklist
Define requirements and develop road map for margin call workflow
Confirm mechanism to flag positions — out-of scope, in-scope and exempt
Review key data attributes required to support regulatory IM and VM processing
Define data elements and feeds to third party for IM reconciliation
Confirm clients that will require legal agreement re-papering based on expected phase-in schedules
Conduct client outreach, education sessions and issue client notifications
Select and implement IM calculation approaches; internal models, external models, standard approach
Develop data mappings and interpolations to support IM calculations
Confirm use of credit assessment — internal, external or combined (only for EU)
Confirm approach for application of the 8% cross-currency haircut for IM (only for EU)
Develop and implement backtesting of IM models
Conduct IM model validation on the conceptual soundness of the IM model(s)
Develop dispute and escalation protocols
Develop client documentation and re-prepare related agreements
Select calculation approach — external model, internal model, standard schedule or combination
Internal control structure enablement
Global program management framework
Margin methodologies/ analytics
Current to future state assessment
Margin/ collateral redesign and implementation
Regulatory readiness package
Reference data management
EY offerings
The complexity of the workflow enhancements and the required technology build will require an average 22 months to deliver tactical and strategic solutions. Use the table below to check if you are ready!
New paradigm for uncleared derivatives in September 2016, the uncleared derivatives market will begin going through wide-ranging changes, such as the universal exchange of variation margin (VM) and two-way initial margin (IM), restriction of eligible forms of collateral, segregation for initial margin and new documentation requirements to govern collateral relationships.
While many impacted organizations have mobilized internal and industry-wide programs to address these regulations, much uncertainty remains as to whether market participants and their counterparties will be adequately prepared for the economic and operational impacts of the margin regulations and their nuances across jurisdictions.
As the leading professional services firm in this space, we offer cross-functional solutions to help our clients prepare, implement and demonstrate compliance with the uncleared margin regulations.
Global regulatory principles • Requires mandatory exchange of VM
• Requires universal two-way exchange of IM to be calculated using a risk-based model or standardized table
• Restricts eligible forms of collateral to highly liquid assets and prescribes methods to derive related haircuts
• Requires that collateral posted for IM is segregated and prohibits rehypothecation
• Defines specific CSA documentation to govern new collateral relationships
• Prescribes a compliance phase-in based on aggregate gross notional amounts beginning 1 September 2016
Key industry challenges • Implementation of global regulations has posed significant challenges to systems,
workflows and procedures for buy-side and sell-side institutions. Reliance on cross-border will be necessary due to inconsistencies and lack of harmonization across jurisdictions.
• Costs and process fragmentation associated with operating separate clearing platforms for listed and OTC derivatives, including different platforms for the US and Europe.
• The time and cross-functional coordination required to build, test and deploy new regulatory-compliant margin models, including integration with up and downstream processes.
• Industry-wide adoption of a regulatory approved risk-based initial margin model for uncleared swaps.
• The ability to produce simulations of margin calls/pre-trade initial margin estimates and cost of margining to assist the front office in pricing of trades is limited.
• Market participants will be required to execute regulatory compliant CSAs and ACAs as early as September 2016, for applicable uncleared swaps. The industry will rely on automated solutions to reduce lengthy bilateral negations.
• Legal agreements are often not integrated; they are stored independently of the margin management system. Inaccurate, insufficient and untimely information is fed down from front-office systems.
• Segregation requirements are expected to produce a surge in the number of counterparty accounts while adding greater complexity to existing segregation models.
• Anticipated massive increase in demand for high-quality cash and non-cash collateral. Many financial institutions lack a holistic and fully transparent view of their pools of eligible collateral or are unable to efficiently mobilize collateral to allocate it against specific exposures.
• Increase in margin call volumes as a result of the regulatory changes, clearing fragmentation, regional offerings and varying legal agreement structures will create scalability issues and promote the need for STP. Firms will also be required to fund larger cash balances to meet expected margin calls.
• Significant need for system integration and data infrastructure overhaul to support funding and operations processes, with many institutions already developing industry-based or proprietary solutions.
Global compliance date and threshold
1 Sep 2016 1 Sep 2017 Sep 1, 2018 1 Sep 2019 1 Sep 2020 1 Mar 2017
Initial margin starting 1 September 2016 — 1 September 2020
Variation margin — 1 September 2016 and 1 March 2017
Exceeds Exceeds
BCBS-IOSCO €3t
US $3.0t
EU €3.0t
Japan: ¥420t
Exceeds
Exceeds
BCBS-IOSCO
€3.0t
US $3.0t
EU €3.0t
Japan: TBD
All covered entities
Exceeds
Exceeds
BCBS-IOSCO €2.25t
US $2.25t
EU €2.25t
Japan: ¥315T
BCBS-IOSCO €1.5t
US $1.5t
EU €1.5t
Japan: ¥210t
BCBS-IOSCO €0.75t
US $0.75t
EU €0.75t
Japan: ¥105t
BCBS-IOSCO €8b
US $8b
EU €8b
Japan: ¥1.1t
Rule comparison across major jurisdictions
Topic Similarities Differences
Covered transactions Physically settled FX forwards and swaps are exempt from IM
[JP] Commodities not included in draft regulations [US] FX forwards and swaps exempt from VM [US] Exclusions apply (e.g., equity options) based on regulatory definition of swap [US] No exemptions for interaffiliate transactions
Covered entities Sovereigns, development banks, and nonfinancial end users are exempt
[N/A] No major differences among jurisdictions
IM model: margin period Ten-day margin period of risk (MPoR)
[EU] MPoR may be larger than 10 days due to concentration risk [US] MPoR may be less than 10 days if maturity of trade is less than 10 days [JP] IM model draft regulations not issued
IM model: netting Netting is not permitted across four broad categories of interest rates/FX, credit, equity and commodity
[EU] Further restrictions on netting via introduction of an “other” category [JP] IM model draft regulations not issued
IM model: historical period Equally weighted observations for no more than five years incorporating a period of financial stress
[EU] No less than three years with a minimum of 25% stress [US] No less than one year of data without [JP] IM model draft regulations not issued
IM model: calibration At least annual calibration [US] At least monthly calibration [JP] IM model draft regulations not issued
VM calculation At least daily calculation [N/A] No differences among jurisdictions
VM collection At least daily collection [EU] Collection permitted within three business days
Eligible collateral 1. Cash for VM in the settlement currency of swap
2. Cash and securities for IM subject to haircuts, including currency mismatch haircut
[US] VM also permitted in USD, not subject to a currency mismatch haircut [EU, JP] Cash or securities for VM subject to haircuts, including currency mismatch [EU] Concentration limits on types of collateral for systemically important institutions (over EUR 1b collected collateral)
Segregation IM segregation at a third party without rehypothecation
[EU, JP] IM may also be segregated through other legally effective means
Documentation Netting and margining to be legally documented
[EU] At least annual legal review of netting enforceability [JP] No explicit documentation requirements in draft regulations
Near-term areas of focus checklist
Define requirements and develop road map for margin call workflow
Confirm mechanism to flag positions — out-of scope, in-scope and exempt
Review key data attributes required to support regulatory IM and VM processing
Define data elements and feeds to third party for IM reconciliation
Confirm clients that will require legal agreement re-papering based on expected phase-in schedules
Conduct client outreach, education sessions and issue client notifications
Select and implement IM calculation approaches; internal models, external models, standard approach
Develop data mappings and interpolations to support IM calculations
Confirm use of credit assessment — internal, external or combined (only for EU)
Confirm approach for application of the 8% cross-currency haircut for IM (only for EU)
Develop and implement backtesting of IM models
Conduct IM model validation on the conceptual soundness of the IM model(s)
Develop dispute and escalation protocols
Develop client documentation and re-prepare related agreements
Select calculation approach — external model, internal model, standard schedule or combination
Internal control structure enablement
Global program management framework
Margin methodologies/ analytics
Current to future state assessment
Margin/ collateral redesign and implementation
Regulatory readiness package
Reference data management
EY offerings
Uncleared margin reform Get ready — it’s coming soon
EY | Assurance | Tax | Transactions | Advisory About EY EY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working world for our people, for our clients and for our communities. EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. For more information about our organization, please visit ey.com. Ernst & Young LLP is a client-serving member firm of Ernst & Young Global Limited operating in the US. EY is a leader in serving the global financial services marketplace Nearly 43,000 EY financial services professionals around the world provide integrated assurance, tax, transaction and advisory services to our asset management, banking, capital markets and insurance clients. In the Americas, EY is the only public accounting organization with a separate business unit dedicated to the financial services marketplace. Created in 2000, the Americas Financial Services Organization today includes more than 6,900 professionals at member firms in over 50 locations throughout the US, the Caribbean and Latin America. EY professionals in our financial services practices worldwide align with key global industry groups, including EY’s Global Wealth & Asset Management Center, Global Banking & Capital Markets Center, Global Insurance Center and Global Private Equity Center, which act as hubs for sharing industry-focused knowledge on current and emerging trends and regulations in order to help our clients address key issues. Our practitioners span many disciplines and provide a well-rounded understanding of business issues and challenges, as well as integrated services to our clients. With a global presence and industry-focused advice, EY’s financial services professionals provide high-quality assurance, tax, transaction and advisory services, including operations, process improvement, risk and technology, to financial services companies worldwide. © 2016 All Rights Reserved. 1601-1807951 Score no. 1030 ED None This material has been prepared for general informational purposes only and is not intended to be relied upon as accounting, tax or other professional advice. Please refer to your advisors for specific advice. ey.com
Contacts Roy Choudhury Principal Office: +1 212 773 9299 [email protected]
Janina Polo Senior Manager Office: +1 212 773 2486 [email protected]
Prakash Rao Executive Director Office: +1 212 773 2188 [email protected]
John Boyle Senior Manager Office: +1 212 773 5412 [email protected]
Setu Pandya Senior Manager Office: +1 212 773 2437 [email protected]
Uncleared margin reform Get ready — it’s coming soon
EY | Assurance | Tax | Transactions | Advisory About EY EY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working world for our people, for our clients and for our communities. EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. For more information about our organization, please visit ey.com. Ernst & Young LLP is a client-serving member firm of Ernst & Young Global Limited operating in the US. EY is a leader in serving the global financial services marketplace Nearly 43,000 EY financial services professionals around the world provide integrated assurance, tax, transaction and advisory services to our asset management, banking, capital markets and insurance clients. In the Americas, EY is the only public accounting organization with a separate business unit dedicated to the financial services marketplace. Created in 2000, the Americas Financial Services Organization today includes more than 6,900 professionals at member firms in over 50 locations throughout the US, the Caribbean and Latin America. EY professionals in our financial services practices worldwide align with key global industry groups, including EY’s Global Wealth & Asset Management Center, Global Banking & Capital Markets Center, Global Insurance Center and Global Private Equity Center, which act as hubs for sharing industry-focused knowledge on current and emerging trends and regulations in order to help our clients address key issues. Our practitioners span many disciplines and provide a well-rounded understanding of business issues and challenges, as well as integrated services to our clients. With a global presence and industry-focused advice, EY’s financial services professionals provide high-quality assurance, tax, transaction and advisory services, including operations, process improvement, risk and technology, to financial services companies worldwide. © 2016 All Rights Reserved. 1601-1807951 Score no. 1030 ED None This material has been prepared for general informational purposes only and is not intended to be relied upon as accounting, tax or other professional advice. Please refer to your advisors for specific advice. ey.com
Contacts Roy Choudhury Principal Office: +1 212 773 9299 [email protected]
Janina Polo Senior Manager Office: +1 212 773 2486 [email protected]
Prakash Rao Executive Director Office: +1 212 773 2188 [email protected]
John Boyle Senior Manager Office: +1 212 773 5412 [email protected]
Setu Pandya Senior Manager Office: +1 212 773 2437 [email protected]