Non-Cleared Margining – APRA CPS226 Update

APRA’s update to CPS226 the other day mainly related to clarification on aspects of substituted compliance. While everyone is focused on non-cleared margining, especially those taking effect 1 Sept 2017, firms should not forget to work through the Risk Mitigation requirements outlined in section 71-95, taking effect 1 March 2018. Especially where similar requirements dealing with counterparties under EMIR and Dodd Frank were avoided or not implemented.