Adrian Lee & Partners

While the extension of the phase-in requirements for initial and variation margin is welcome, Adrian Lee & Partners strongly disagrees with Article 5 GEN which exempts FX Forwards and FX Swaps from initial margin only. The firm proposes that Article 5 GEN be amended to exempt such instruments from the requirement to collect variation margin in addition to the exemption for initial margin. Please see the attached for further details.
Kevin Mahon