Submission #62

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Japanese Bankers Association

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

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 the attachment.

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 the attachment.

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 the attachment.

Respondent to this consultation are invited to highlight their concerns on the requirements on trading relationship documentation. See the attachment.

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

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

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

Name of organisation Japanese Bankers Association