Template:M summ 2018 CSD Other CSA: Difference between revisions

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In the {{imcsd}}, the {{imcsdprov|Other CSA}} concept weighs in to handle the complex job of teasing apart what is real regulatory initial margin and what is merely stuff your dealer wants you to pony up for a rainy day, regardless of whether regulators think you need to. That, in the old days, we used to call an {{csaprov|Independent Amount}}, and that lineage is preserved in its modern label “{{imcsdprov|Margin Amount (IA)}}”, to be contrasted with {{imcsdprov|Margin Amount (IM)}} for the compulsory regulatory stuff.
[[Other CSA - IM CSD Provision|In]] the {{imcsd}}, the {{imcsdprov|Other CSA}} concept weighs in to handle the complex job of teasing apart what is real regulatory initial margin and what is merely stuff your dealer wants you to pony up for a rainy day, regardless of whether regulators think you need to. That, in the old days, we used to call an {{csaprov|Independent Amount}}, and that lineage is preserved in its modern label “{{imcsdprov|Margin Amount (IA)}}”, to be contrasted with {{imcsdprov|Margin Amount (IM)}} for the compulsory regulatory stuff.


What you need to bear in mind here is that for your other margin arrangement to count as an Other CSA and for {{icds}}’s careful engineering to kick in, you will need to specify it as an {{imcsdprov|Other CSA}} in paragraph 13, unless it is already a Credit Support Annex under this {{isdama}} — because in that case it is already a Transaction under the Agreement, see? (Don ’t forget that Credit Support Deeds ''aren’t'' part of the {{isdama}} and ''do'' need to be specified as an {{imcsdprov|Other CSA}}. Even though, strictly speaking they’re deeds and not annexes and — oh well, how sad, never mind.
Now it falls to me to note that {{imcsdprov|Other CSA}}is a rather unfortunate term, for a bunch of quite subtle reasons but, thanks to some perfidious accidents of history, {{icds}} was more or less obliged to call it this. As with so many of ISDA’s catastrophic drafting choices, we are where we are.


If I were more entrepreneurial than I am, I would make a witty tea-towel up about this, like that one with the rules of cricket on it, so dads could have it up in their home bars, like my father did, next to the poster of the chimpanzee playing tennis and scratching his arse.
What you need to bear in mind here is that for your non-regulatory margining arrangement to count as an {{imcsdprov|Other CSA}} and for {{icds}}’s careful engineering to kick in, you will need to specify it as an {{imcsdprov|Other CSA}} in paragraph {{imcsdprov|13}}, unless it already is a [[Credit Support Annex]] under this {{isdama}} — because in that case it is already a {{isdaprov|Transaction}} under the {{isdaprov|Agreement}}, see? (Don’t, by the way, forget that [[Credit Support Deed]]s ''aren’t'' part of the {{isdama}} and ''do'' need to be specified as an {{imcsdprov|Other CSA}}. Even though, strictly speaking they’re deeds and not annexes and — oh well, how sad, never mind.
 
If I were more entrepreneurial than I am, I would make a witty tea-towel up about this, like that one with the rules of cricket on it, so dads like mine could have it up in their home bars, next to the poster of the chimpanzee playing tennis and scratching his arse.
 
In any case, prime brokers: you need to designate the prime brokerage agreement as an {{imcsdprov|Other CSA}}. Even though it isn’t a CSA.
 
Why did {{icds}} include the throw-away comment about the {{imcsdprov|Control Agreement}}, which isn’t itself a collateral arrangement at all, not being an {{imcsdprov|Other CSA}} at the end, when it clearly isn’t and no-one said it was in the first place? Who knows? Who ''cares''?
 
... Except that it ''would'' be fun to specifically designate a {{imcsdprov|Control Agreement}} as a {{isdaprov|Credit Support Document}} just to see what happened. I mean why you ''would'', I don’t know, other than just to set off the smoke alarms in your [[dealer]]’s [[legal department]] — but come to think of it, that’s reason enough. You have to make your fun where you can get it, friends.