The hundreds of firms in scope of UMR phase six should get an easier time if legal documentation is consolidated on one platform. This is the idea as custodian BNY Mellon publishes its triparty and third-party account control agreements (ACAs) on ISDA Create.

It was in early 2019 that the International Swaps and Derivatives Association (ISDA), together with law firm Linklaters, launched ISDA Create. The platform is meant to be able to host all the negotiation and documents needed for market participant firms to comply with the increased initial margin requirements for trades that are not centrally cleared (the “uncleared margin rules”, UMR). The rules are being phased in, with the larger firms across the world already on board through phases 1–5. But the highest number of firms fall under phase 6, which becomes effective in September 2022.

“Market participants are now able to access BNY Mellon’s triparty and third-party account control agreements (ACAs) via the ISDA Create platform, enabling firms to negotiate and agree those documents online with full digital capture of the resulting legal data,” ISDA writes in its press release.


“Having both BNY Mellon’s ACAs – which govern the terms of collateral segregation and management between a custodian and two trading counterparties – and ISDA’s credit support documents available on ISDA Create means BNY Mellon clients have the opportunity to complete the legal documentation required for regulatory IM on a single platform, simplifying compliance efforts.”