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CloudMargin and Margin Tonic, a service provider specialising in collateral and post-trade domains, have partnered to launch a global Average Aggregated Notional Amount (AANA) calculation service.
The initiative will combine CloudMargin technology with Margin Tonic regulatory consultancy services to help firms address Uncleared Margin Rules compliance.
Firms brought into scope for Phase 5 of UMR – based on their AANA calculations for March, April and May of 2021 – were required to begin exchanging Initial Margin (IM) from 1 September for trading of non-cleared over-the-counter (OTC) derivatives. A much larger group of mainly buy-side firms, estimated at almost 800 firms by the International Swaps and Derivatives Association (ISDA), is expected to fall into scope for Phase 6, which takes effect on 1 September 2022. This follows AANA calculations conducted in March through May of the same year for most jurisdictions.
Even for those firms under the threshold (US$8 billion in the US or €8 billion in the European Union) and not in scope for Phase 6, there is a regulatory need to perform ongoing year-on-year AANA calculations to assess if firms will come into scope any year after September 2022.
AANA calculation rules can be complex, with product scope and calculation methods varying by jurisdiction. Firms also often encounter AANA challenges such as consolidation of data from multiple trade sources, lack of AANA regulatory guidance and unclear treatment of funds, including multi-manager funds.
In addition, trading volumes and products will change over time. Consequently, AANA calculations should be performed on a regular basis. A proactive monitoring approach ensures firms will have full readiness in place, with no late surprises on their AANA results and rushed compliance solutions, says CloudMargin.
Simon Millington, head of business development at CloudMargin, says: “Calculating AANA is the first step toward determining if an institution is in scope for UMR. Many firms don’t realise that they’ll need to maintain these AANA calculations on an ongoing basis, whether or not they fall into scope for Phase 6. Clients can choose to work with us to automate and optimise their entire collateral workflow as desired, if and when they exceed the threshold.”
Chris Watts, co-founder of Margin Tonic, adds: “We have performed and advised on AANA calculations across multiple UMR phases, for a variety of different firms and set-ups. Having clarity on AANA status ensures that firms can prepare for compliance, for the heavy front-to-back changes. Too often, we have seen firms perform AANA calculations too late, or not regularly enough, causing a rush to compliance with unfit solutions and high compliance risk, with the potential to impact their ability to trade.
“By introducing the joint AANA service with our partners at CloudMargin, we provide an AANA one-stop shop, combining our advice with their technology. In turn, we will remove AANA burden for our clients, allowing them to focus on key decisions, either for compliance readiness or for trading adjustments to remain out of scope entirely.”
