Many seasoned attorneys will agree that remediating an enormous amount of documentation to ensure regulatory compliance is no easy feat. The volume of repapering necessary for compliance with the new rules governing margin requirements for non-centrally cleared derivatives (UMR) presented new challenges, exposed structural weaknesses, and provided many lessons learned which can be applied to any documentation remediation effort. Many UMR initiatives suffered significant hurdles that contributed to delays and missed deadlines. Common among the various challenges faced were the dearth of talent in the quantities needed, and the limited technology and data management solutions utilized.
