<p><span>It may seem premature to be thinking about September 2022, the point the final phase of the initial margin (IM) rules for non-cleared derivatives will come into effect. It’s not. Phase five in September this year underlined the challenges in-scope firms will face and the need to start preparing early, particularly when it comes to custodian onboarding. Fortunately, the recent publication of key custodial documents on the ISDA Create online negotiation platform points to a path forward that will make the compliance process simpler and more efficient and save phase...