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Concept

When approaching the architecture of counterparty risk, we begin not with definitions, but with function. The core challenge in any bilateral financial agreement is managing the potential for loss stemming from a counterparty’s failure to meet its obligations. The system designed to mitigate this risk is built upon two distinct, yet complementary, pillars Initial Margin and Variation Margin.

Viewing these as mere accounting entries is a fundamental error. They are dynamic risk management protocols, each with a unique operational purpose, cadence, and system-level impact.

Initial Margin (IM) functions as a performance bond, a pre-funded reserve of capital established at the inception of a derivatives contract. Its primary role is to secure the surviving party against the potential future exposure that could arise during the chaotic period immediately following a counterparty default. This is the critical window, lasting several days, between the last successful collateral exchange and the point at which the defaulted portfolio can be hedged or replaced. IM is therefore a forward-looking mechanism.

It is calculated not on the current value of the trade, which could be zero at inception, but on a sophisticated estimate of how much the trade could move against the surviving party in a stressed market scenario. This capital is held in a state of readiness, segregated at a third-party custodian, and is untouchable by either counterparty during the normal course of business. It represents a foundational layer of security, a static pool of capital calibrated to absorb the shock of a sudden default.

Initial Margin is the strategic reserve set aside to cover the projected costs of a counterparty default over a multi-day close-out period.

Variation Margin (VM), in contrast, is a tactical, high-frequency settlement protocol. Its function is to neutralize the present-day, mark-to-market (MtM) exposure of a derivatives contract. As the value of the underlying asset fluctuates, one party will have an unrealized gain, and the other an equal unrealized loss. VM is the mechanism that facilitates the daily, or even intraday, transfer of collateral from the losing party to the winning party, effectively resetting the net exposure between them to zero.

This is a reactive protocol, driven by the constant flux of the market. It prevents the accumulation of large, unsecured credit exposures over the life of the trade. Unlike the segregated nature of IM, VM is a direct transfer of title; the collateral received can be used by the recipient. It is the system’s circulatory network, constantly moving capital to where it is needed to maintain equilibrium.

The fundamental distinction lies in their temporal focus and purpose. IM addresses a potential future event ▴ a default ▴ and provides a buffer for the unknown market moves that would follow. VM addresses the current reality of the trade’s value, ensuring that today’s losses are collateralized today.

One is a strategic defense fund; the other is a daily tactical adjustment. Understanding this functional separation is the first principle in designing a robust and compliant collateral management architecture.


Strategy

The strategic management of initial and variation margin extends far beyond mere compliance with regulatory mandates. For an institutional trading desk, the margin framework is a critical determinant of capital efficiency, liquidity risk, and ultimately, profitability. The architectural decisions made around collateral management directly impact a firm’s ability to deploy capital and manage its balance sheet. The implementation of the Basel Committee on Banking Supervision (BCBS) and International Organization of Securities Commissions (IOSCO) framework for non-centrally cleared derivatives has transformed this from a back-office function into a central strategic concern.

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Capital Efficiency and Liquidity Planning

The primary strategic tension in margin management is the balance between risk mitigation and capital efficiency. Initial Margin, by its nature, locks up high-quality capital for the duration of a trade. A key strategic objective is to minimize the IM footprint without compromising risk standards. This involves several layers of analysis.

  • Portfolio Netting ▴ The most powerful tool for optimizing IM is portfolio-level netting. By holding offsetting positions with the same counterparty, a firm can significantly reduce its overall potential future exposure and, consequently, its IM requirement. The Standard Initial Margin Model (SIMM) is designed to recognize these offsets within specific asset classes. Strategic portfolio construction, therefore, becomes a tool for margin optimization.
  • Collateral Optimization ▴ While cash is the simplest form of collateral, it is also a drag on returns. A sophisticated collateral strategy involves using non-cash assets, such as high-quality government bonds, to satisfy margin requirements. This requires a system capable of managing eligibility criteria, concentration limits, and haircut schedules, transforming idle assets into productive capital.
  • Threshold Management ▴ The BCBS-IOSCO framework includes a €50 million initial margin threshold per counterparty group. A strategic decision for firms is how to allocate this threshold across different business lines and legal entities to maximize trading capacity before IM obligations are triggered. This requires a centralized view of exposure across the entire organization.
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How Does the Regulatory Framework Shape Margin Strategy?

The BCBS-IOSCO rules are the primary driver of margin strategy for non-centrally cleared derivatives. These rules were a direct response to the systemic risks identified during the 2008 financial crisis. The framework’s core objective is to ensure that sufficient collateral is in place to withstand a major counterparty default, thereby preventing contagion. For a trading firm, the strategy is to build an operating model that is not only compliant but also commercially viable within this new regulatory landscape.

Variation Margin practices, while long-standing, were standardized and made mandatory by the framework. The daily settlement of MtM exposures reduces the risk of large, uncollateralized losses building up over time. The strategic imperative here is operational robustness ▴ the ability to accurately value portfolios, issue and respond to margin calls, and settle collateral movements on a strict daily schedule without fail. Any breakdown in this process introduces operational risk and potential disputes.

The introduction of mandatory two-way Initial Margin for covered entities was the framework’s most significant change. It created a substantial new demand for high-quality collateral and necessitated the development of new infrastructure for segregation and calculation. The strategy here is one of proactive readiness, including the implementation of models like SIMM and the establishment of custodial accounts well ahead of regulatory deadlines.

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Comparative Strategic Functions of Margin Types

The following table outlines the distinct strategic roles of Initial and Variation Margin within an institutional risk management framework.

Strategic Dimension Initial Margin (IM) Variation Margin (VM)
Primary Risk Mitigated Potential Future Exposure (PFE) following a counterparty default. Current Mark-to-Market (MtM) exposure.
Capital Impact Long-term funding cost for segregated assets (Margin Value Adjustment – MVA). Reduces available capital for other investments. Short-term liquidity impact from daily cash or collateral flows.
Operational Focus Complex, model-based calculation (e.g. SIMM), establishment of custodial accounts, and management of segregated assets. High-frequency, automated process for valuation, margin call issuance, and settlement.
Counterparty Interaction One-time posting at trade inception, with adjustments for portfolio changes. High-stakes negotiation on model parameters and disputes. Continuous daily interaction. Potential for frequent, low-value disputes on valuation.
Optimization Strategy Portfolio netting, collateral substitution, and threshold management to minimize the quantum of locked-up capital. Efficient cash management and streamlined dispute resolution protocols to minimize operational friction.


Execution

Executing a compliant and efficient margin management process requires a sophisticated synthesis of legal documentation, quantitative modeling, and technological infrastructure. For an institutional participant in the non-cleared derivatives market, this is not a discretionary activity; it is a foundational operational capability. The transition from concept and strategy to execution involves a granular, multi-stage process that must be architected with precision.

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The Operational Playbook

Implementing a robust margin framework involves a series of distinct, sequential steps. This playbook outlines the critical path for an institution to establish its margin operations for non-cleared derivatives.

  1. Entity Status Determination ▴ The first step is to determine if the institution and its counterparties qualify as “Covered Entities” under the BCBS-IOSCO framework. This involves calculating the Aggregate Average Notional Amount (AANA) of non-cleared derivatives over a specific measurement period (typically March, April, and May of each year). Exceeding the defined threshold (e.g. $12 billion in Canada) triggers the requirement to exchange margin.
  2. Documentation Remediation ▴ Standard ISDA Master Agreements must be supplemented with a compliant Credit Support Annex (CSA). This legal document governs all aspects of collateral exchange, including eligible collateral types, haircuts, valuation timing, and dispute resolution protocols. For IM, a separate custodial agreement must be established to govern the segregation of assets.
  3. Custodial and Segregation Setup ▴ For Initial Margin, firms must establish accounts with a third-party custodian. The chosen structure must ensure the IM is legally segregated and protected from the insolvency of either the posting party or the receiving party. This involves significant legal and operational due diligence.
  4. Margin Calculation Engine Implementation ▴ The firm must deploy a calculation engine for both VM and IM.
    • For VM ▴ This system must be capable of ingesting daily market data, valuing the entire derivatives portfolio, and calculating the net MtM exposure for each counterparty.
    • For IM ▴ The firm must choose between the standardized schedule (a simple but punitive approach) or implementing a sophisticated model like ISDA SIMM. The vast majority of institutional players opt for SIMM to leverage its netting benefits.
  5. Daily Process Automation ▴ The daily margin call process must be highly automated. This includes issuing calls, responding to calls from counterparties, managing collateral settlement, and tracking all movements. Platforms like AcadiaSoft have become industry utilities for automating these workflows and reconciling portfolio data.
  6. Dispute Management Protocol ▴ A clear, time-bound process for handling margin disputes is essential. The CSA will define the dispute resolution mechanism, which typically involves a period of reconciliation followed by an escalation procedure if the disagreement persists.
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Quantitative Modeling and Data Analysis

The quantitative heart of modern initial margin calculation is the ISDA Standard Initial Margin Model (SIMM). It is a sensitivity-based Value-at-Risk (VaR) model designed to produce a standardized, transparent, and replicable IM calculation. Its adoption is critical for any firm seeking to manage its capital efficiently.

The model works by first calculating the “greeks” (sensitivities) of every trade in a portfolio to a predefined set of risk factors. These sensitivities are then aggregated using specified correlations to arrive at a portfolio-level margin amount. The model is calibrated to a 99% confidence interval over a 10-day margin period of risk.

The SIMM framework provides a standardized language for quantifying and communicating counterparty risk.
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SIMM Product Classes and Risk Factors

The model is structured around four main product classes, which are kept separate for calculation purposes. Within each product class, risks are further broken down into risk classes and buckets.

Product Class Primary Risk Classes Example Risk Factors
Interest Rates & FX Interest Rate, FX, Inflation Yields at 12 standard tenors (e.g. 3M, 1Y, 10Y) for each currency; FX spot rates.
Credit Qualifying (High Yield/Investment Grade), Non-Qualifying Credit spreads at 5 standard tenors for various sectors (e.g. financials, sovereigns).
Equity Equity Spot prices for equities, categorized by sector and market cap.
Commodity Commodity Spot prices for various commodities (e.g. crude oil, natural gas, metals).
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Illustrative SIMM Calculation Snippet

Consider a simplified portfolio with two USD interest rate swaps. The model’s logic flows from risk factor sensitivities to an aggregated margin figure.

Step 1 ▴ Calculate Sensitivities (Delta) The primary input is the portfolio’s sensitivity to moves in the interest rate curve. Let’s assume the net sensitivities (DV01, or dollar value of a basis point) for the portfolio at two key tenors are:

  • 5-Year Tenor ▴ +$15,000 / bp
  • 10-Year Tenor ▴ -$12,000 / bp

Step 2 ▴ Apply Risk Weights SIMM provides specific risk weights for each risk factor. For major currencies, the weight might be around 21 bps for the 5Y tenor and 20 bps for the 10Y tenor.

  • Weighted Sensitivity (5Y) ▴ $15,000 21 = $315,000
  • Weighted Sensitivity (10Y) ▴ -$12,000 20 = -$240,000

Step 3 ▴ Intra-Bucket Aggregation The model uses a correlation parameter (e.g. g = 0.27 for interest rates) to aggregate the weighted sensitivities within the same bucket (in this case, the USD interest rate bucket).

Formula ▴ sqrt( S_5Y^2 + S_10Y^2 + 2 g S_5Y S_10Y )

Calculation ▴ sqrt( 315,000^2 + (-240,000)^2 + 2 0.27 315,000 (-240,000) ) = sqrt( 9.92e10 + 5.76e10 – 4.08e10 ) = sqrt(1.16e11) = $340,588

This result represents the Delta Margin for this specific risk bucket. The full SIMM calculation would repeat this process for all other sensitivities (Vega, Curvature) and across all risk classes and product classes to arrive at the total IM requirement.

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Predictive Scenario Analysis

Let’s walk through a case study involving “Quantum Hedge Fund” (QHF) and “Global Dealer Bank” (GDB). On July 31, 2025, QHF enters into a 10-year, non-cleared USD interest rate swap with GDB to hedge its portfolio duration. Both are covered entities under the margin rules.

Day 1 (T+0) ▴ Trade Execution & IM Posting The trade is executed with a notional of $250 million. At inception, the swap’s mark-to-market is zero, so no Variation Margin is exchanged. However, an Initial Margin calculation is required. Using the ISDA SIMM model, GDB’s risk system calculates that the potential future exposure of this trade warrants an IM of $5.2 million.

QHF’s operations team verifies the calculation. QHF instructs its custodian to transfer $5.2 million of U.S. Treasury bonds to GDB’s segregated account at a third-party custodian. The system is now armed.

Day 2 to Day 5 ▴ Normal Market Operations Over the next few days, interest rates fluctuate modestly. Each day, both parties value the swap. Let’s say on Day 2, rates move slightly in QHF’s favor, making the swap’s MtM +$150,000 for QHF. GDB’s operations system automatically sends a VM call to QHF for this amount.

QHF’s system reconciles the valuation, and upon agreement, GDB transfers $150,000 in cash to QHF. This daily settlement of VM keeps the current exposure between the parties flat.

Day 6 ▴ Stress Event A surprise economic data release causes a sharp drop in long-term interest rates. The value of QHF’s swap position increases dramatically. At the end of the day, the swap’s MtM is now +$3.1 million for QHF. GDB is now facing a significant loss.

The automated VM call is generated ▴ QHF is owed $2.95 million (the $3.1 million total MtM less the $150,000 already received). GDB honors the call and transfers the funds. The VM system has worked as intended, preventing a large unsecured credit exposure from building up.

Day 10 ▴ Counterparty Default Imagine an alternate scenario where, following the stress event on Day 6, GDB suffers catastrophic losses from other positions and declares bankruptcy before the market opens on Day 10. QHF is now exposed. Its swap, which was worth +$3.1 million, is now a claim against a bankrupt entity.

The last VM payment was made on Day 6. This is precisely the scenario IM was designed for.

QHF’s risk management team immediately begins to find a replacement swap in the market. Due to the market volatility, it takes three days to execute a new swap with another dealer on equivalent terms. During this 3-day close-out period, rates have continued to move against GDB’s defaulted position, and the cost to replace the swap is now $4.8 million. QHF has suffered a loss.

However, it can now make a claim on the $5.2 million in segregated Initial Margin. This collateral is used to cover the $4.8 million replacement cost. The remaining $400,000 is returned to GDB’s estate. The IM acted as the designated capital buffer, absorbing the losses from the default and protecting QHF from financial harm.

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System Integration and Technological Architecture

The execution of a modern margin management system is fundamentally a technology and data integration challenge. A patchwork of spreadsheets and manual processes is no longer viable. A robust architecture requires several integrated components:

  • Data Management Layer ▴ This forms the foundation. It requires reliable, real-time feeds for all necessary market data (yield curves, FX rates, volatilities) and position data from the firm’s core trading systems (OMS/EMS).
  • Valuation and Risk Engine ▴ This is the core analytical component. It must be capable of pricing every instrument in the portfolio and calculating all the sensitivities required by the SIMM model. This engine is often the same one used for enterprise-wide market risk management.
  • Margin Calculation and Workflow Platform ▴ This system ingests the sensitivities from the risk engine and performs the SIMM aggregation. It also manages the entire margin call workflow ▴ generating calls, validating incoming calls, and tracking the status of each collateral movement. Many firms use specialized vendor platforms (like AcadiaSoft) that act as a central hub, connecting to counterparties and custodians.
  • Collateral Management System ▴ This component maintains an inventory of available collateral, optimizes the allocation of securities to meet margin calls, manages haircuts and eligibility schedules, and instructs settlement with custodians.
  • Integration and Messaging ▴ The entire architecture is held together by robust integration. This is often achieved through APIs and standardized messaging protocols like the Financial products Markup Language (FpML), which is used to communicate trade details, and messaging from platforms like SWIFT for collateral settlement instructions.

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References

  • Basel Committee on Banking Supervision and the International Organization of Securities Commissions. “Margin requirements for non-centrally cleared derivatives.” March 2015.
  • International Swaps and Derivatives Association. “ISDA SIMM® Methodology.” Version 2.4, July 2021.
  • Harris, Larry. “Trading and Exchanges ▴ Market Microstructure for Practitioners.” Oxford University Press, 2003.
  • Hull, John C. “Options, Futures, and Other Derivatives.” Pearson, 10th Edition, 2017.
  • Gregory, Jon. “The xVA Challenge ▴ Counterparty Credit Risk, Funding, Collateral, and Capital.” Wiley Finance, 3rd Edition, 2015.
  • International Swaps and Derivatives Association. “ISDA Margin Survey.” Published Annually.
  • Financial Stability Board. “Global Monitoring Report on Non-Bank Financial Intermediation.” Published Annually.
  • Office of the Superintendent of Financial Institutions Canada. “Margin Requirements for Non-Centrally Cleared Derivatives ▴ Guideline.” April 2020.
  • Clifford Chance. “BCBS-IOSCO minimum standards for margin requirements for uncleared derivatives.” March 2013.
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Reflection

The architecture of margin is a direct reflection of a firm’s philosophy on risk, capital, and operational excellence. The distinction between initial and variation margin is the foundational syntax of a language used to manage counterparty risk in a complex financial system. Having explored the concepts, strategies, and execution protocols, the critical question moves from “What are they?” to “How does our implementation of these protocols create a competitive advantage?”

Consider your firm’s collateral management framework not as a static compliance utility, but as a dynamic system. Does it merely prevent losses, or does it actively enhance capital efficiency? Is your technology architecture a rigid constraint, or does it provide the flexibility to optimize collateral and respond to market opportunities? The systems you build to manage margin are a microcosm of your entire operational platform.

Their resilience, efficiency, and intelligence are a direct measure of your institution’s capacity to navigate the complexities of modern markets. The ultimate edge is found in transforming a regulatory necessity into a strategic asset.

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Glossary

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Counterparty Risk

Meaning ▴ Counterparty risk, within the domain of crypto investing and institutional options trading, represents the potential for financial loss arising from a counterparty's failure to fulfill its contractual obligations.
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Variation Margin

Meaning ▴ Variation Margin in crypto derivatives trading refers to the daily or intra-day collateral adjustments exchanged between counterparties to cover the fluctuations in the mark-to-market value of open futures, options, or other derivative positions.
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Risk Management

Meaning ▴ Risk Management, within the cryptocurrency trading domain, encompasses the comprehensive process of identifying, assessing, monitoring, and mitigating the multifaceted financial, operational, and technological exposures inherent in digital asset markets.
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Potential Future Exposure

Meaning ▴ Potential Future Exposure (PFE), in the context of crypto derivatives and institutional options trading, represents an estimate of the maximum possible credit exposure a counterparty might face at any given future point in time, with a specified statistical confidence level.
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Counterparty Default

Meaning ▴ Counterparty Default, within the financial architecture of crypto investing and institutional options trading, signifies the failure of a party to a financial contract to fulfill its contractual obligations, such as delivering assets, making payments, or providing collateral as stipulated.
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Mark-To-Market

Meaning ▴ Mark-to-Market (MtM), in the systems architecture of crypto investing and institutional options trading, refers to the accounting practice of valuing financial assets and liabilities at their current market price rather than their historical cost.
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Mtm

Meaning ▴ MtM, or Mark-to-Market, is an accounting and valuation method that assesses the fair value of an asset or liability based on its current market price.
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Potential Future

The Net-to-Gross Ratio calibrates Potential Future Exposure by scaling it to the measured effectiveness of portfolio netting agreements.
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Collateral Management

Meaning ▴ Collateral Management, within the crypto investing and institutional options trading landscape, refers to the sophisticated process of exchanging, monitoring, and optimizing assets (collateral) posted to mitigate counterparty credit risk in derivative transactions.
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Non-Centrally Cleared Derivatives

Meaning ▴ Non-Centrally Cleared Derivatives in crypto refer to derivative contracts, such as options or futures on crypto assets, that are executed and settled bilaterally between two counterparties without the intermediation of a central clearing house (CCP).
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Capital Efficiency

Meaning ▴ Capital efficiency, in the context of crypto investing and institutional options trading, refers to the optimization of financial resources to maximize returns or achieve desired trading outcomes with the minimum amount of capital deployed.
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Initial Margin

Meaning ▴ Initial Margin, in the realm of crypto derivatives trading and institutional options, represents the upfront collateral required by a clearinghouse, exchange, or counterparty to open and maintain a leveraged position or options contract.
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Standard Initial Margin Model

Meaning ▴ The Standard Initial Margin Model (SIMM) is a standardized framework utilized by clearinghouses and prime brokers to calculate the initial margin required for a portfolio of derivatives and other financial instruments.
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Simm

Meaning ▴ SIMM, or Standardized Initial Margin Model, is an industry-standard methodology for calculating initial margin requirements for non-centrally cleared derivatives, developed by the International Swaps and Derivatives Association (ISDA).
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Margin Requirements

Meaning ▴ Margin Requirements denote the minimum amount of capital, typically expressed as a percentage of a leveraged position's total value, that an investor must deposit and maintain with a broker or exchange to open and sustain a trade.
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Bcbs-Iosco

Meaning ▴ The BCBS-IOSCO represents a collaborative effort between the Basel Committee on Banking Supervision and the International Organization of Securities Commissions, two preeminent global standard-setting bodies.
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Cleared Derivatives

Meaning ▴ Cleared Derivatives are financial contracts, such as futures or options, where a central clearing house (CCP) interposes itself between the original counterparties, mitigating credit risk through novation.
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Credit Support Annex

Meaning ▴ A Credit Support Annex (CSA) is a critical legal document, typically an addendum to an ISDA Master Agreement, that governs the bilateral exchange of collateral between counterparties in over-the-counter (OTC) derivative transactions.
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Csa

Meaning ▴ CSA, an acronym for Credit Support Annex, is a crucial legal document that forms part of an ISDA (International Swaps and Derivatives Association) Master Agreement, governing the terms for collateralizing derivative transactions between two parties.
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Margin Calculation

Meaning ▴ Margin Calculation refers to the complex process of determining the collateral required to open and maintain leveraged positions in crypto derivatives markets, such as futures or options.