The U.S. non-cleared margin regulations require an earlier calculation period than other jurisdictions to determine whether a party is in-scope for initial margin.
Phase 5 IM calculation period in the U.S. is June-August, 2019.
To assist market participants that may be subject to the Phase 5 initial margin (IM) requirements in the U.S., ISDA has prepared the a summary of the U.S. requirements for calculating the average aggregate notional amount (AANA) for Phase 5 for a compliance date of September 1, 2020. The requirements for calculating AANA in the U.S. deviate substantively from the requirements in other jurisdictions.
Remember, whatever jurisdiction you may be in, Cassini can: