Purpose: The Trade Life Cycle Events Guide for Non-Cleared Margin was initially established and agreed by market participants through a series of discussions held within the ISDA
Initially Developed June 2016;
WGMR Margin and Collateral Processing and Portfolio Integrity Workstreams in 2016. The workstreams were comprised of a wide array of market participants from buy and sell side Prepared for publication May 2019
institutions. The working group both identified and agreed the list of trade events as well as agreed to the general consensus captured in the below matrix as to whether or not these with no substantive changes made.
identified trade events would bring a legacy non cleared swap transaction into scope for the new margin rules. The intention of this list is to provide an agreed market guide for firms
to utilize in order to comply with certain aspects of the non cleared margin rules within their respective jurisdictions. No firm is legally bound or compelled in any way to follow any
determinations made within this list.
Please see the legal disclaimers below for further details.

ISDA Trade Life Cycle Events Guide for Non Cleared Margin
Category
Trade Event

Amendments andCancellations

Amendment (i.e. Correction)
Economically Immaterial Amendment
Economically Material Amendment
Cancellation

Trade events

New Trade which is In-scope Product (post-compliance date)

Detail* Bring into scope for Uncleared margin?
Yes or No(Working Group ConsensusView)
Amending details that were originally No
input incorrectly.
No (no change in pricing)
Trade booked in error andsubsequently cancelled.

New Trade which is Out-of-scope Product (post-compliancedate)
New Trade which is Out-of-scope Product in one jurisdiction
and In-scope Product for another jurisdiction (postcompliance date)
Increase
Full Termination
Partial Termination

Allocation
Cleared Positions

Full Novation

A bilaterally executed agreement toincrease the notional on thetransaction.
Full Unwind
Partial Unwind

Original Unallocated "Block" Trade
allocated to principal parties post go
live.
Original Bilateral Trade (the "alpha"trade), post-compliance.
Cleared Position ("beta" and"gamma" trades)
Remaining party

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Notes

Does M&CP Consensus Align With
Clearing Y/NYY

Yes (change in pricing)
NoNY

Yes

N/ANo

N/A

Yes, for the entity subject to The CSA specifies applicable
the regulatory regime
regimes per the two
where the product is incounterparties.
scope.
Yes
Generally, firms seem to feel theentire trade comes into scope.

N/ANoNoYYNo

The partial unwind would notbring the remaining portion of thetrade into scope. (Similar as underclearing mandate logic.)
Yes for allocations of trades
entered into post-effective date.

N

N/A

No

N/A

No

N/A

Yes

No, if the remaining party and thestep-in party are eligible for aninter-affiliate exemption.

YCategory

Trade EventTrade events* Bring into scope for UnNotes
Does M&CP Consensus Align With
cleared margin?
Clearing Y/NYes or No(Working Group ConsensusView)
Yes
No, if the remaining party and theYstep-in party are eligible for aninter-affiliate exemption.

Step inPartial Novation

Swaption Exercise
Compression Event

Cash Settlement
Intrinsic changes

DetailAmortizing Notionals

Step outNo

Remaining party

Yes

No, if the remaining party and thestep-in party are eligible for aninter-affiliate exemption.

Y

Step in

Yes

No, if the remaining party and thestep-in party are eligible for aninter-affiliate exemption.

YStep out
Exercise of a Swaption/Resulting
Swap from the exercise of aSwaption.
Original Trade - TerminatedOriginal Trade - Amendment
New resultant trade

NoNo

The actual cash settlement of fees,payments, etc.
Changes to the notional during thecourse of a trade.

NoNo
NoYes

YYYYNo, if all trades within an industry- Yes - Any contract in a clearing
wide run compression were legacy obligation product which is enteredtrades.
into or novated between in-scopecounterparties after the clearing
obligation is in force must becleared. This is regardless ofwhether the contract results from acompression exercise or similar.

YNo

If pursuant to the original contract
terms.

YDividend ResetsNo

If pursuant to the original contract
terms.

N/A

Equity ResetsNo

If pursuant to the original contract
terms.

N/A

No

If pursuant to the original contract
terms.

Y

Rate Resets

Changes to the floating rate of a
tradePage 2

Category

Trade Event

Other

Successor Events

Other

Credit Events

Other

Corporate Actions

Detail* Bring into scope for UnNotes
Does M&CP Consensus Align With
cleared margin?
Clearing Y/NYes or No(Working Group ConsensusView)
The reference entity specified in the No
If pursuant to the original contract
N/Aterms.
transaction is succeeded by anotherentity.
Default on a transaction e.g.,No
If pursuant to the original contract
Yterms.
bankruptcy/restructuring/ obligation
default.
Including:No, assuming related to the If pursuant to the original contract
N/Aterms.
underlying equity.
Bonus Issue/Capitalisation issue

If pursuant to the original contract
terms.

N/ASpecial Dividend

If pursuant to the original contract
terms.

N/A

Spin-OffIf pursuant to the original contract
terms.

N/AStock Split/Change in nominalvalue

If pursuant to the original contract
terms.

N/A

Reverse Stock split/Change innominal value

If pursuant to the original contract
terms.

N/A

No, if option to convert isnegotiated pre-compliance date.
Yes, if post-compliance date, you
amend swap originally referencing
ADR to instead reference theunderlying stock.

N/A

OtherConversions

Parties mutually agreeing andYes
consenting to a conversion postcompliance date which results in amaterial amendment. Would notinclude a conversion documented
pre-compliance date as an event due
to take place in the future (i.e. postcompliance date). Example would beswap on an ADR that is converted toswap on the underlying stock asagreed by both parties, or a stock isdual listed and is converted from a
GBP line to a HK line as agreed byboth parties.

Other

Publicly Traded / Listed Swap Index

Swap is removed/changed in theNoindex by the administrator of theindex (i.e. not at the discretion of thedealer or counterparty).
Example would be quarterly roll forindex CDS. Would not include
rebalancing of the index.

Page 3N/A

Category

Trade Event

Other

Customized Basket Index Swap

Other

Reference Entity Succession Event

Other

DetailConstituents of the basket arechanged at the discretion of thedealer or counterparty.
Example would be rebalancing thebasket by closing a swap on an oldticker and booking that swap on anew ticker.

* Bring into scope for Uncleared margin?
Yes or No(Working Group Consensus
View)
Yes

Notes

Does M&CP Consensus Align With
Clearing Y/NN/ANo

If pursuant to original contract
terms (i.e., no change in pricing).

N/A

Addition of Reference Underlyer to Long Portfolio or Short
Portfolio
Removal of Reference Underlyer from Long Portfolio orShort Portfolio

Creation of a new swap contract on Yes
Security XYZ.
Partial or full termination of existing Noswap contract on Security XYZ.

No, if initial agreement allowed
addition or removal.

N/A

Other

Increase in Notional Amount for Existing Reference
Underlyer

Increasing long or short exposure to Yes
Security XYZ.

No, if a function of a corporate
action or a stock split.

N/A

Other

Decrease in Notional Amount for Existing Reference
Underlyer

Decreasing long or short exposure to No
Security XYZ in a portfolio swapwrapper.

OtherLegal Disclaimer

This document does not constitute legal, accounting or financial advice. It reflects feedback received by ISDA from swap market participants (including bothdealer and buy-side firms) who participated in the Working Group. As with other guidance and market practice statements that ISDA disseminates, parties arefree to choose alternate means of addressing the specific facts of their situation. Nothing in the document is contractually binding on any party or amends any
ISDA Master Agreement or ISDA Credit Support Annex. ISDA assumes no responsibility for any use of this document and undertakes no duty to update it toreflect future regulatory or market developments.

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N/A

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UNDER NO CIRCUMSTANCES SHALL ISDA BE LIABLE TO ANY PARTY, REGARDLESS OF THE
FORM OF ACTION, ARISING FROM OR IN CONNECTION WITH INFORMATION IN THISDOCUMENT OR ANY PERSON'S USE OF THIS DOCUMENT, OR FOR ANY INDIRECT, SPECIAL,CONSEQUENTIAL, INCIDENTAL OR PUNITIVE DAMAGES THAT MAY RESULT FROM THEUSE OF THIS DOCUMENT.