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AcadiFi
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VM_Ops_Henri2026-04-06
frmPart IICredit Risk

How does variation margin work mechanically, and how does it differ from initial margin in terms of purpose and daily operations?

I understand the concept of variation margin for FRM Part II — it covers the daily change in mark-to-market. But I'm unclear on the exact operational process. When is VM calculated? What happens if there's a dispute over the MTM? And how does VM interact with the initial margin and threshold?

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Variation margin (VM) is the daily exchange of collateral that reflects changes in the mark-to-market value of a derivatives portfolio. Unlike initial margin (which covers potential future exposure), VM settles the realized gains and losses that have already occurred, effectively converting the derivative into a daily-settled instrument.\n\nVM vs. IM: Different Purposes:\n\n| Feature | Variation Margin | Initial Margin |\n|---|---|---|\n| Purpose | Settle realized P&L | Cover future potential losses |\n| Calculation basis | Current MTM change | Potential exposure over MPOR |\n| Direction | Flows to the party with gains | Posted by both parties |\n| Frequency | Daily (sometimes intraday) | Recalculated periodically |\n| Asset form | Cash only (post-2017 rules) | Cash or eligible securities |\n| Segregation | Not segregated (belongs to receiver) | Must be segregated |\n| Rehypothecation | Permitted (it's a settlement) | Prohibited |\n\nDaily VM Process:\n\n`mermaid\ngraph TD\n A[\"T: Valuation time
(usually end of business)\"] --> B[\"Calculate net MTM
of all trades under CSA\"]\n B --> C[\"Compare to previous
day's net MTM\"]\n C --> D[\"VM call amount =
Today's MTM - Yesterday's MTM
- Current collateral held\"]\n D --> E{\"VM amount >
Threshold + MTA?\"}\n E -->|Yes| F[\"Issue VM call
by notification deadline\"]\n E -->|No| G[\"No call — change
below operational minimum\"]\n F --> H[\"Counterparty delivers
collateral by T+1\"]\n H --> I[\"Reconcile and confirm
receipt of collateral\"]\n`\n\nWorked Example:\nPeakstone Capital and Elsworth Bank have the following CSA terms:\n- Threshold: $0 (full collateralization)\n- MTA: $250,000\n- Eligible VM collateral: USD cash only\n\nDay 1: Portfolio MTM = +$3.2 million (Elsworth owes Peakstone)\n- VM call: $3.2 million\n- Elsworth transfers $3.2 million cash to Peakstone\n\nDay 2: Portfolio MTM = +$2.8 million (MTM declined by $400K)\n- Required collateral: $2.8 million\n- Currently held: $3.2 million\n- VM return: Peakstone returns $400,000 to Elsworth\n\nDay 3: Portfolio MTM = +$3.0 million (MTM increased by $200K)\n- Additional collateral needed: $200,000\n- $200K < $250K MTA, so no margin call is triggered\n- Residual unsecured exposure: $200,000\n\nDay 4: Portfolio MTM = +$3.6 million (MTM increased by $600K from Day 2 level)\n- Cumulative under-collateralization: $3.6M - $2.8M (held) = $800K\n- $800K > $250K MTA, so margin call for $800,000\n\nDispute Resolution:\n\nIf Elsworth calculates the MTM as +$2.9 million while Peakstone calculates +$3.6 million on Day 4:\n- The undisputed amount ($2.9M) is transferred immediately\n- The disputed portion ($700K) enters a resolution process\n- Most CSAs require transfer of the agreed-upon amount within the notification deadline\n- Disputes are typically resolved within 2-3 business days using independent pricing sources\n\nPost-2017 Rules (Phase 1-6 UMR):\n\nSince March 2017, mandatory VM rules require:\n- Daily VM exchange for all OTC derivatives between covered entities\n- VM must be in cash for single-currency swaps (no bonds)\n- Zero threshold is the regulatory standard (contractual thresholds may still apply for uncovered entities)\n\nPractice margin calculations in our FRM Part II question bank.

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