Submission #47

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The Bank of New York Mellon Corporation

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

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

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. NA

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

Respondent to this consultation are invited to highlight their concerns on the requirements on trading relationship documentation. N/A

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

Does 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 Trust.

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

Upload files ESAs 2nd Margin Proposal-Custody Bank Response.pdf

Name of organisation The Bank of New York Mellon Corporation