Response to second Joint Consultation on draft RTS on risk-mitigation techniques for OTC-derivative contracts not cleared by a CCP

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Respondents are invited to comment on whether the requirements of this section concerning the concentration limits address the concerns expressed on the previous proposal.

We agree with the proposals that non-systemic firms would not be required to diversify their collateral. We agree that to require this would be overly burdensome for non-systemic market participants.

Respondents are invited to comment on the requirements of this section concerning the legal basis for the compliance.

We agree with the proposals. However, we would support including flexibility by allowing for the ability for legal review to be provided internally rather than requiring external legal opinions.

Does this approach address the concerns on the use of cash for initial margin?

Yes, we agree that cash should be excluded from these obligations.

Name of organisation

IG Markets Limited