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Response to second Joint Consultation on draft RTS on risk-mitigation techniques for OTC-derivative contracts not cleared by a CCP
Go backRespondents are invited to comment on the proposal in this section concerning the timing of calculation, call and delivery of initial and variation margins.
NARespondent are invited to provide comments on whether the draft RTS might produce unintended consequence concerning the design or the implementation of initial margin models.
NARespondents are invited to comment on whether the requirements of this section concerning the concentration limits address the concerns expressed on the previous proposal.
NARespondent to this consultation are invited to highlight their concerns on the requirements on trading relationship documentation.
NARespondents are invited to comment on the requirements of this section concerning the legal basis for the compliance.
NADoes this approach address the concerns on the use of cash for initial margin?
See attached joint comment letter from State Street, BNY Mellon, and Northern TrustRespondents are invited to comment on the requirements of this section concerning treatment of FX mismatch between collateral and OTC derivatives.
NAName of organisation
The Northern Trust Corporation
