The impact of UMR on buy side firms can be significant in operational and collateral costs, and while on the surface the change to split phase 5 into two phases seems fairly benign by just moving the regulatory deadline out a year, it actually presents opportunities for both phase 5 and phase 6 firms.

This handy briefing will enable Phase 5 firms to review their average aggregate notional amount (AANA) levels and take steps to move themselves into Phase 6.

For phase 6 firms there is more time to review and modify trading behaviour, as well as balancing counterparty agreements to maximise the $50m posting threshold, which can reduce or possibly eliminate the cost of UMR.