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[ CASE STUDIES ]

UMR Phase 6 Compliance

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When we found ourselves unexpectedly caught under UMR Phase 5, CORSA turned a regulatory crisis into a strategic advantage. By partnering with Bloomberg and influencing the product roadmap, they helped us not only meet compliance but secure a tailored solution.

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Client Overview

The client, a large pension fund, was unexpectedly caught under Phase 5 of the Uncleared Margin Rules (UMR) due to its aggregate average notional amount exceeding regulatory thresholds. While most buy-side firms were preparing for Phase 6, the client found itself facing an accelerated and underserved compliance timeline—without off-the-shelf technology solutions available to meet its requirements.

 

At the time, vendors had not accounted for pension funds being in-scope under Phase 5, and many platforms, including Bloomberg, were still developing their tools with Phase 6 asset managers in mind. The client engaged CORSA to urgently assess the challenge and deliver a compliant, scalable solution.

The Challenge

01
Client unexpectedly caught under Phase 5 UMR thresholds. No vendor readiness—Bloomberg and others had solutions in-flight for Phase 6 only.
02
Time-critical compliance deadline with significant legal and operational implications.
03
No internal infrastructure for initial margin (IM) calculation, SIMM methodology, or collateral workflows.
04
Need for rapid coordination across legal, compliance, investment, and operations teams.

Our Solution

CORSA identified an opportunity to partner with Bloomberg during the early design stages of its MARS SIMM solution:

Vendor Collaboration

Worked directly with Bloomberg’s product team to co-develop the UMR compliance solution.

Product Influence

Provided critical design input, aligning Bloomberg’s roadmap with real-world pension fund requirements.

Pilot Implementation

Acted as the pilot client for Bloomberg’s MARS SIMM for UMR.

Legal & Documentation

Partnered with legal counsel to review and amend CSAs, collateral schedules, and IM exchange provisions.

Operational Readiness

Designed workflows for IM threshold monitoring and calculation, margin call automation, and dispute resolution.

The Result

01
Achieved full UMR Phase 5 compliance ahead of the regulatory deadline.
02
Delivered a tailored Bloomberg AIM and MARS solution aligned to the client’s investment strategy and structure.
03
Reduced vendor risk by partnering on solution design and testing.
04
Implemented scalable IM and margin management workflows embedded in existing tools.
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[ Client Testimonial ]

“When we found ourselves unexpectedly caught under UMR Phase 5, CORSA turned a regulatory crisis into a strategic advantage. By partnering with Bloomberg and influencing the product roadmap, they helped us not only meet compliance but secure a tailored, scalable solution that’s built for our business. Their speed, leadership, and understanding of Bloomberg AIM made all the difference.”

What happened next

Following successful implementation, CORSA was retained to support future phases of regulatory change and to advise on broader derivatives and margin strategy enhancements.

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