Navigating Uncleared Margin Rules

Are you ready for initial margin?

Find Capital-Efficient Solutions to UMR Challenges

Since Uncleared Margin Rules (UMR) went live in 2016, only a small number of firms have been impacted by Phases 1-4. But by September 2022, an estimated 1,000+ additional entities will be subject to UMR for initial margin (IM).

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UMR Timeline

Getting ready for UMR can be a significant, time-intensive undertaking for firms not familiar with posting initial margin. Knowing if your firm is impacted is critical to plan accordingly.

Thresholds in the US & EU

UMR Phase US (in USD), EU (in EUR) Initial Margin Compliance Date
Phase 5 50 billion 1-Sep-21
Phase 6 8 billiion 1-Sep-22

Observation Phases 5 & 6 in the US & EU

Phase 5 - Sept 1, 2021 Compliance Date Phase 6 - Sept 1, 2022 Compliance Date

Observation Period:

March, April and May 2021

Observation Period:

March, April and May 2022

Calculated daily on US, monthly in EU Calculated daily on US, monthly in EU
AANA threshold: > 50 billion (USD, EUR) AANA threshold: > 8 billion (USD, EUR)

*New dates released by BCBS & IOSCO, and each are subject to respective jurisdictions.

What's In Scope for UMR

Average Aggregate Notional Amount (AANA)

AANA is what regulators use to determine whether a firm is in scope for IM in Phases 5 & 6. Asset managers, banks, hedge funds, corporates, pensions and more may be subject to the requirements.

Which derivatives are in-scope

AANA is based on the open gross notional value of all non-centrally cleared derivatives during the designated calculation observation period for the phase.

Uncleared OTC Derivatives

Not Included:
Cleared Instruments

  • FX options 
  • Non-deliverable forwards (NDFs)
  • Physical FX forwards
  • Swaptions
  • Hedging trades
  • IR caps & Floors
  • Equity swaps and forwards
  • Centrally cleared OTC swaps
  • Exchange-traded derivatives

This is not an exhaustive list. For a detailed list, visit ISDA.

Standardised initial margin schedule

Asset class

Initial margin requirement
(% of notional exposure)

Credit: 0–2 year duration


Credit: 2–5 year duration


Credit 5+ year duration






Foreign exchange


Interest rate: 0–2 year duration


Interest rate: 2–5 year duration


Interest rate: 5+ year duration




How and when AANA is calculated

Where you are located (US or EU) will help determine how your firm’s AANA is calculated, when/if you will be captured under UMR Phases 5 & 6, and when you must start posting IM.


Using Adjusted Interest Rate Total Return futures to trade equity financing levels along the curve

Isolate the financing spread differential for equity financing level trades with Adjusted Interest Rate Total Return futures, a liquid and efficient alternative to Total Return Swaps (TRS).
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Uncleared margin: The changing needs of buy-side firms

Join triResolve's Raf Pritchard and to discuss the initial margin calculation and collateralization challenges for firms coming into scope under phases five and six of the uncleared margin rules.
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UMR: can participants capitalise on extra time?

For financial institutions, the recent decision by regulators to delay the final two phases of the uncleared margin rules (UMR) certainly provides additional time, but it needs to be used effectively to seek out operational efficiencies across the business.
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Webinar: Getting ready for initial margin compliance

Watch this webinar to hear discussions on key topics to help you determine if you’re captured by the requirements, and if you are, how to successfully navigate the implications for your business.
Register >

Our Solutions

Find out how our global solutions can help you throughout the entire UMR process, from meeting IM requirements, adding capital efficiencies, to reducing costs and core business disruptions.

Reduce your total notional outstanding

If your firm is close to a UMR threshold, explore multiple ways to lower your AANA.

Use compression services

Use triReduce to compress notional outstanding and line items in your OTC derivatives portfolio, via multilateral compression cycles.

Scalable for use in multiple asset classes for cleared and non-cleared relationships:

  • Rates
  • FX
  • Credit
  • Commodities

Part of the market-leading TriOptima suite of solutions
Read more >

Voluntarily clear OTC products

Use our multi-asset OTC cleared offering to add the margin efficiencies of clearing to your OTC portfolio.

Cleared IRS in 24 currencies USD swaptions
Read more >

11 NDFs, 26 CSFs, 7 FX options
Read more >

Use CME CORE to calculate and compare IM for listed and cleared OTC CME Group products.
Read more >

Additional tools
Portfolio margining, coupon blending, compression services
Read more >

Move vanilla bilateral exposures to futures

Use our diverse futures and options lineup to replicate vanilla bilateral OTC exposures and reduce in-scope notional outstanding, as follows.

Rate swaps
Eurodollar and Treasury futures and options, MAC swap futures
Read more >

FX forwards
FX monthlies, FX options, FX Link 
Read more >

Equity total return swaps
S&P 500 Total Return futures including new Adjusted Interest Rate (AIR) Total Return futures, Dividend futures, Select Sector futures
Read more >

Get help meeting daily compliance needs

Explore solutions to integrate daily IM calculation, communication and reconciliation tasks into the collateral management process for your derivatives portfolio.

Calculate daily margin requirements

Use triCalculate, which has licensed the ISDA SIMM margin model, to calculate IM exposure.
Read more >

Use CME CORE to calculate and compare IM for listed and cleared OTC CME Group products.
Read more >

Agree to margin calls with your counterparties

Use triResolve Margin to calculate and automatically agree to your Initial Margin calls and collateral movements with your counterparties.
Read more >

Resolve margin disputes with ease

Use Acadia’s IM Exposure Manager to help identify exposure differences and resolve disputes.
Read more >

Minimize margin requirements

Minimizing exposure against each counterparty and optimizing net funding amounts can help lower bilateral margin requirements.

Optimize counterparty risk exposures

Use triBalance to rebalance bilateral and cleared counterparty risk for greater margin efficiencies and to keep your portfolio market-risk neutral.

triBalance takes the next step in portfolio optimization by innovating a trusted, simple, uniform process for managing your portfolio risk and counterparty exposure.
Read more >

Use voluntary clearing

Use CME Group cleared OTC products where possible to lower requirements from 10-day margin on uncleared bilateral exposures to the 5-day margin on cleared OTC.

You also can add counterparty netting benefits by clearing all trades in a single account instead of bilaterally across multiple counterparties (UMR margins are calculated at the counterparty level).
Read more >

Shift to futures

Use CME Group futures and options where possible in place of vanilla swaps to further reduce requirements to the 1-2 day margin of standardized listed products.

As with voluntary clearing, CME Group futures and options offer counterparty netting benefits.
Read more >

FX Case Study: Add Up to 89% Capital Efficiencies

See the difference UMR solutions can make to your IM costs. The example below shows a real portfolio of FX options. By applying one of our solutions to address IM costs, the client can add significant potential savings. Clearing delta hedges would add to the IM efficiencies of using OTC clearing or exchange-traded derivatives.

Read Full Study

UMR Resources

FCA Fact Checker

Find out more about the margin requirements for uncleared derivatives that started to be phased in 2017.

ISDA Checklist

View ISDA’s 8-Step Guide to getting ready for Initial Margin regulatory requirements.


Get answers to common questions on UMR and compliance.

Greenwich TCA Study

Buyside firms may save up to 70% in execution costs on some trades by using listed FX options.

ISDA Resource Hub

View tools, thought leadership articles and guides for your non-cleared margin rules needs

Learn More About Our Initial Margin Solutions

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