With September approaching, this is a good moment to check in on where your firm stands with the Uncleared Margin Rules (UMR) as it relates to CFTC covered swap entities.
Update
Following Up: ISDA Publishes Updated AANA Self-Disclosure Letter
As firms work through their UMR status ahead of the September 1 compliance date, ISDA has published an update worth flagging: a revised Regulatory Initial Margin AANA Self-Disclosure Letter (SDL), released on July 17, 2026, along with an accompanying Answer Sheet. You can view the ISDA release here.
What's New
The updated SDL supersedes the prior versions published in 2018, 2019, and 2021. It gives market participants a standard way to communicate the information counterparties need to determine which trading relationships are, or may become, subject to regulatory initial margin requirements. Specifically, the new SDL allows an entity to:
Disclose whether it is part of a group for AANA purposes
Identify which AANA thresholds it (or its group) has exceeded, by regime
Expressly state that it does not exceed, and does not expect to exceed, any AANA threshold
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Why This Matters Now
For firms still confirming their status ahead of September, the updated SDL is the standard tool counterparties will expect to use to exchange this information. Completing and exchanging an accurate SDL is often the first concrete step in the broader UMR documentation process, since it's what determines whether, and how, IM calculations and supporting agreements need to move forward with a given counterparty.
How Quadrangle Can Help
Once your firm has determined its AANA status, Quadrangle can manage the SDL process on your behalf, including:
Preparing and processing your firm's SDL and Answer Sheet based on your firm's AANA determination
Coordinating SDL exchange with counterparties as part of your broader UMR outreach
Connecting SDL results to the underlying documentation, so custody, credit support, and account control agreements move forward without delay
If you haven't yet completed the updated SDL, or want support managing the exchange and documentation process, we're here to help.
With September approaching, this is a good moment to check in on where your firm stands with the Uncleared Margin Rules (UMR) as it relates to CFTC covered swap entities. If your firm's exposure has grown, you may be newly in scope this year. If you're already working through your documentation, there's a clear and manageable path to the deadline. If you haven't yet confirmed your firm's status, now is a good time to find out, so you have the runway you need to get everything in place.
Who's In Scope and By When
For entities under the CFTC's margin regime, the compliance date falls on September 1. Whether your firm is newly in scope depends on your Average Aggregate Notional Amount (AANA), calculated over March, April, and May of this year. Firms whose uncleared OTC derivatives exposure crossed the $8 billion threshold during that window are now subject to UMR.
The $8 billion AANA threshold captures a broad range of firms, including:
Hedge funds, private equity funds, and family offices with meaningful OTC derivatives books, particularly those active in FX forwards, swaps, and other non-cleared products
Asset managers whose consolidated group exposure crosses the threshold, even if no single fund does on its own
Corporates and pension funds with hedging programs large enough to reach the calculation
Smaller institutional entities encountering these requirements for the first time
Because AANA is reassessed annually at the consolidated group level, firms can move in and out of scope from year to year, so it's worth confirming your status even if you weren't in scope last cycle.
What the Deadline Requires
UMR requires in-scope firms to segregate initial margin on covered OTC derivatives. In practice, this means:
Calculating required collateral, typically using ISDA's Standard Initial Margin Model (SIMM)
Establishing a custody relationship, segregating the required initial margin with an independent custodian
Negotiating and executing supporting documentation, including custody arrangements, credit support documents, eligible collateral schedules, and account control agreements
Getting Ahead of September
The documentation process is very manageable when there's time to work through it properly. If your firm is already underway, staying on this timeline should keep you on track for a smooth path to September. If your firm hasn't yet started, or hasn't confirmed whether it's in scope, the next few weeks are the right window to begin: reaching out now still leaves enough time to negotiate the necessary documentation comfortably ahead of the deadline.
How Quadrangle Can Help
Quadrangle manages the end-to-end documentation process that UMR compliance depends on. Our team can:
Negotiate custody, credit support arrangements, and account control agreements on your firm's behalf
Guide your firm through ISDA Create, powered by the CreateIQ platform and related onboarding steps to ensure timely execution and coordination with your custodian
Structure counterparty relationships to support both compliance and operational efficiency
Through our QDS platform, every key term across your UMR-related agreements is tracked, auditable, and easy to access, keeping compliance simple rather than stressful.
Whether you're still confirming if your firm is in scope or ready to begin papering the required agreements, we're here to help.
