Yet another mismatch is looming in the delivery of post-crisis derivatives reforms across borders - this time in an area that participants say will have the deepest competitive implications for the banking industry of any of the 2009 G20 reforms. European regulators have yet to finalise rules requiring the collateralisation of uncleared derivatives, but remain publicly committed to an implementation schedule that begins this September. The timeline matches a US regime that was finalised in December, but the most recent European proposal contains a handful of material differences from the US version. European rules require margin to be posted against a broader scope of products -including equity options - than US rules. The European framework also limits the amount of one type of collateral that counterparties can post to back their derivatives trades, while the US version does not.
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