The Working Group on Margining Requirements, led by the International Organization of Securities Commissions and the Basel Committee on Banking Supervision, has released revised proposals on margining of uncleared over-the-counter derivatives. Dealers are concerned about the procyclical nature of the proposals and that they would result in disputes. "We acknowledge the steps the group has taken in an attempt to address the concerns of the industry, and the use of thresholds is certainly helpful in times of peace," ISDA CEO Robert Pickel said. "But when things get crazy in times of war -- namely, when market volatility spikes -- there can be a severe amplification effect."

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