|
|
FCA understands that some firms may not be in a position to exchange variation margin fully in compliance with the Regulatory Technical Standards by 1 March 2017 despite their efforts to date.
In the supervision of firms’ progress, FCA will take a risk-based approach and use judgement as to the adequacy of progress, taking into account the position of particular firms and the credibility of the plans they have made.
Where a firm has not been able to comply fully, FCA will expect it to be able to demonstrate that it has made best efforts to achieve full compliance, and be ready to explain how it will achieve compliance in as short a time as practicable for all in-scope transactions entered into from 1 March 2017. It will expect detailed and realistic plans to be in place, which we may request to see at any time.
FCA expects firms to have come into compliance within the coming few months.