Our articles are written by experts in their field and include individual barristers, solicitors, academics, judges, and leading firms in relevant areas of practice. JIBFL offers authoritative insights into global banking and financial law, providing essential updates for legal practitioners and policymakers. Covering key topics like lending, security interests, derivatives, debt capital markets, banking and finance related disputes, crypto, FinTech and financial regulation, JIBFL serves as a trusted resource for navigating complex legal challenges and staying informed in the financial sector. If you would like to contribute, please email Amanda.Cohen2@lexisnexis.com.
EMIR 3.0, post-trade risk reduction services and the initial margin threshold: an unintended consequence
© Copyright LexisNexis 2025. All rights reserved.
Post trade risk reduction (PTRR) services are not new to over-the-counter (OTC) derivatives markets. Through EMIR 3.0, policymakers acknowledged their function (reducing counterparty credit risk and/or operational risk) and fostered their usage by laying down the exemption from the clearing obligation. Admittedly, however, they did not consider any impact of PTRR on margin requirements for non-centrally cleared OTC derivatives. Performing PTRR – specifically portfolio rebalancing – is set to increase the aggregate average notional amount (AANA). As the latter is calculated to determine whether the initial margin (IM) threshold is exceeded, counterparties may opt to avoid using PTRR to avoid becoming subject to the burdensome IM requirements. An outcome not in line with the intention to foster PTRR.
If you are already a User, sign in
Or you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Alternatively you can subscribe here to read unlimited content.
