Important decisions must be made about how organizations will meet MI requirements. Companies must agree on custodian banks for the publication of MIs, agree with counterparties on thresholds and ATMs, agree on appropriate safeguards and define internal minimum standards for the guarantee plan, decide on the use of schedule or simm™ define the IM methodology and define an internal customer priority for live efforts. If you choose to use the SIMM™ model, apply for your license from ISDA. It is important that, as soon as a party is subject to the rules, the requirements of the UMR apply only to IM exchanges in U-OTC transactions concluded after the effective date. For example, when a fund is subject to the rules from September 1, 2021, only transactions entered into after that date will be subject to the MLI rules.  An important consideration, however, is that old transactions carried out before the date of entry into force may continue to be included in the scope of the rules when certain events in the business life cycle take place. Among these events, there are things like the increase in the nominal amount of a trade or the novice of a trade. These life cycle events were discussed and agreed upon by a working group of industry practitioners prior to the first phase of MI implementation. The full list of these lifecycle events is available in ISDA.
 The rules require a framework away from insolvency without re-use of collateral. Therefore, the initial margins in favour of the secured party are transferred under a security interest regime and a specific custody framework must be implemented to protect assets in the event of a delay by one of the parties to the trade. This framework is based on a „trilateral“ account control agreement (ACA) that has been signed between the parties and a custodian bank. For several years, there have been long debates and discussions around the UMR. During this period, the rules, which initially appeared to revise the way many funds handle collateral for U-OTC transactions, were reduced and their last two phases of implementation were postponed on two separate occasions. Finally, on 3 April 2020, the Basel Committee on Banking Supervision („BCBS“) and the International Organization of Securities Commissions (IOSCO) announced an additional one-year delay for Phases 5 and 6 due to COVID-19.  As previously stated, VM rules were introduced in 2017. These are the rules for immediate ims that come into play gradually. The implementation of the rules on the initial margin will be progressively accelerated at each new stage. However, Phases 5 and 6 will involve a large number of institutions that will have to comply within the next two years.
According to the July 2018 ISDA and SIFMA study, more than 9,000 new security relationships are expected to exist. And unlike the margin of variation, which is a well-established concept for most companies, the initial margin is quite new, especially for institutional investors. . . .