Submission #42

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Czech Banking Association

Respondents are invited to comment on the proposal in this section concerning the treatment of non-financial counterparties domiciled outside the EU. see attached file

Respondents are invited to comment on the proposal in this section concerning the timing of calculation, call and delivery of initial and variation margins. see attached file

Respondent are invited to provide comments on whether the draft RTS might produce unintended consequence concerning the design or the implementation of initial margin models. see attached file

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

Respondent to this consultation are invited to highlight their concerns on the requirements on trading relationship documentation. see attached file

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

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

Respondents are invited to comment on the requirements of this section concerning treatment of FX mismatch between collateral and OTC derivatives. see attached file

Upload files CBA - JC-CP 2015_002 on Risk Management Techniques for OTC derivatives_20150701.pdf

Name of organisation Czech Banking Association