Uncleared Margin Rules - Frequently Asked Questions

Is UMR only for banks and hedge funds?

No. Initial margin rules apply to any firm who is in-scope of their local margin rules and has an AANA during the relevant observation period for each year at or above the minimum threshold. If your AANA is above the threshold, your firm will be subject to Initial margin rules. For further detail on the UMR timeline & How & When AANA is calculated, see cmegroup.com/umr respective sections.

The observation period for Phase 5 (Sep 2020 deadline) for U.S. covered entities is as follows: June, July and August 2019
For firms covered by jurisdictions, in the rest of world the Phase 5 observation period is as follows:  March, April and May 2020.

I am a corporate or a pension fund, am I exempt from UMR?

No, as with the previous question, it depends on your threshold.

Does my AUM dictate or affect whether I am impacted by UMR?

No, whether you will be in-scope is based on your AANA, which is calculated on open gross notional outstanding of non-centrally cleared derivatives.

I only trade derivatives as hedge transactions, am I still potentially impacted by UMR?

Hedging tools are not exempt from derivatives used in the AANA calculation, which in turn is used to determine whether a firm is in-scope for UMR.  See the tables in “Who and What Is In Scope for UMR?” section.

Will Initial Margin rules impact my prime brokerage relationships?

It may. Please reach out to your prime broker.

If I am above the IM threshold what does that mean? And what should I consider implementing as a result?

TriOptima offers a helpful guide for how to prepare for initial margin rules.
Be sure to also check out the CME Group UMR solutions resource page.

What tools are available to me to help delay or mitigate the impacts of Initial Margin rules?

CME Group offers several solutions to help you overcome UMR challenges, across bilateral and cleared markets. Explore our comprehensive offerings here.


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