About the GMRA Legal Opinions
Regulators require repo transactions to be documented under robust written legal agreements, such as the GMRA, supported by regularly updated legal opinions, as a condition of recognising the reduction of credit risk by collateral and close-out netting in the calculation of regulatory capital requirements and large exposures. Reasoned legal opinions are required to confirm that, in the event of a legal challenge, the relevant courts and administrative authorities would find that, where a counterparty fails owing to default, bankruptcy, liquidation or any other similar circumstance, the regulated firm’s claims and obligations pursuant to the GMRA would be limited to a net sum under the law of the relevant jurisdiction(s), and which meets certain other requirements.
The ICMA GMRA Legal Opinions are accessible on aosphere. Members who do not have an account are requested to contact support@aosphere.com.
Tier 1, 2a and 2b members have access to all opinions as part of their membership. Tier 3 members are given access to five legal opinions annually as part of their membership fee. Above five, Tier 3 members will be charged the subscription fee for any number of additional legal opinions. Associate members will need to subscribe to access any legal opinions. Official institution members, including central banks, debt management offices, development banks and regulators, are exempt from the subscription service.
Non-members of ICMA are not permitted to subscribe.
A list of the jurisdictions covered by the opinions is provided below.
| GMRA Legal Opinions - jurisdiction coverage |
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| Anguilla Argentina Armenia Australia Austria Bahamas Bahrain Barbados Belgium Bermuda Brazil British Virgin Islands Canada Cayman Islands Croatia Curaçao and Sint Maarten Cyprus Czech Republic Denmark |
England Estonia Finland France Georgia Germany Ghana Greece Guernsey Hong Kong Hungary India Indonesia Ireland Israel Italy Japan Jersey Kazakhstan |
Latvia Liechtenstein Lithuania Luxembourg Malaysia Malta Mauritius Mexico The Netherlands New Zealand Northern Ireland Norway Oman People's Republic of China Philippines Poland Portugal Qatar Romania |
Russia Scotland Serbia Singapore Slovakia Slovenia South Africa South Korea Spain Sweden Switzerland Taiwan Thailand Republic of Türkiye United Arab Emirates USA |
A matrix providing detailed information on the jurisdictions and counterparty types covered by the 2025 legal opinions can be found here.
A matrix setting out which annexes to the GMRA 2000 and GMRA 2011 are covered by the 2025 legal opinions can be found here.
