Regulatory authorities in participating countries are now in the process of developing margin rules for noncleared derivatives in light of the international framework. The framework requires both financial firms and systemically important nonfinancial firms that trade derivatives to collect both variation margin and initial margin, as is the case for centrally cleared derivatives.
The initial margin requirements represent a significant change  9  The Tier 1 common equity ratio for the 18 largest bank holding companies increased from 5.9 percent in December of 2007 to 11.3 percent in September of 2013. For more information, see the FR Y-9C “Consolidated Financial Statements for Holding Companies (PDF)” reporting form.