BCBS - CPMI - IOSCO Joint Working Group on Margin Workstream 2
Survey of Non-Bank Intermediaries

**** Updated data and feedback survey available for download ****

UPDATE - Margin Survey

Due to time constraints some intermediaries were unable to submit a response to the initial intermediary margin survey prior to the 31st May modified deadline. In light of the feedback received the JWGM has agreed to reopen the survey to allow additional time so that as many intermediaries as possible can participate.

Firms that have already submitted a response are encouraged to resubmit a response if their initial submission did not include answers to all questions, especially Tier 1 and Tier 2 questions. The updated “Intermediary Survey WS2 Version 1.1.1” document for a description of Tier 1 and Tier 2 questions can be found in the download link below.

Feedback Scope

Intermediaries are invited to comment on the following elements of the proposed Version 1.1.1 survey (found in the download link below):

  • The feasibility of responding to all Tier 1 and Tier 2 questions by August 2, and, if not possible, recommended alternative deadlines per Tier 1 or Tier 2 question;
  • Rationale or explanation if the firm cannot respond to a particular Tier 1 or Tier 2 question by August 2; and
  • Adding completely new Tier 1 or Tier 2 questions not already asked in the previous version that could be answered by the August 2 deadline.

Restructuring existing questions is out of scope during the feedback process. The JWGM will not be able to modify the existing questions so as to make Version 1.1.1 survey responses compatible and stackable with existing Version 1.0.0 survey submissions.

Feedback Transmission

If the firm’s primary regulator is a BCBS member, the firm should follow QIS submission instructions from the firm’s BCBS member supervisor.

If the firm’s primary regulator is an IOSCO member, the firm should submit feedback directly to IOSCO at the email address below.

Feedback on the survey from both channels will be forwarded to the Secretariats for synthesis.

Deadlines (Subject to Feedback from Intermediaries)

25th June: Please complete and return the feedback collection survey to the IOSCO Secretariat ([email protected]).

2nd August: Please complete and return the data survey to the IOSCO Secretariat ([email protected]).

We would once again like to thank you for your time and participation in this important exercise. During the course of this new data collection process, please forward any questions to [email protected].

Download Intermediary Survey WS2 Version 1.1.1

Download the Intermediary Margin Survey (previous version)


The G20, as part of its the work programme to enhance the resilience of non–bank financial intermediation (NBFI) sector, has called for a review of margining practices in cleared and uncleared markets, including with regards to the preparedness of market participants for margin calls.

To achieve this objective, IOSCO, CPMI and the BCBS have set up a Joint Working Group on Margin (JWGM), co-chaired by the Bank of England and the US CFTC.

Project Mandate

The JWGM is examining the following areas, taking into account both initial and variation margins:

  • Margin in cleared and uncleared markets during the March market turmoil, including clearing member-client dynamics (“workstream 1”);
  • Margin practice transparency, predictability and volatility during the March market turmoil across various markets, jurisdictions and margining models (“workstream 2”); and
  • Liquidity management preparedness of market participants (especially non-banks) to meet margin calls and the actions they took to do so (for example, ability of firms to use or transform high quality liquid assets) (“workstream 3”).


To undertake such a data-driven analysis, the JWGM’s workstream 2 is undertaking an ad-hoc survey to better understand the impact of margin calls in uncleared markets and margin calls related to house and client clearing activities from the firms’ perspective.

The data required is outlined in the data template, which can be downloaded from the link below. Respondents are asked to participate on a best effort basis and, as appropriate, to include any additional information or accompanying documents.

Before submission, respondents are asked to remove any identifying codes. The data will then be further anonymised before analysis. All data will be held in strict confidence and stored securely. Access to the data is only through a dedicated unique login and password and the analytical team will be subject to a confidentiality agreement. All data submissions, after being anonymised will be securely transmitted to the BCBS where the results will be merged with bank entity-level data held on the e-BIS system. The analytical team will undertake analysis on the combined data to obtain necessary insights.

The JWGM strongly encourages responses from smaller banks that are not part of the QIS framework and from non-bank firms. This is an important opportunity to help inform the focus and direction of future policies to address systemic risks in NBFI, including interactions between CCPs, banks and non-banks and cross-border spill-overs.