FIA has responded to the EBA consultation on draft Regulatory Technical Standards (RTS) related to implementation of a new prudential regime for investment firms in the EU. The response provides feedback from the perspective of the clearing members, and it is limited to the proposed draft RTS specifying the calculation of the amount of the total margin for the calculation of K-CMG under IFR Article 23(3). FIA recommends an amended definition of ‘total margin required’ and for a change in the calculation methodology of K-CMG in case of multiple clearing members. The response also highlights limitations in the use of K-CMG both in terms of territorial and personal scope and seeks clarification of clearing members specific concerns.
