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Questionnaire for CDS CCPs on Protection of Customer Initial Margin - page 17 / 32





17 / 32


Excess Margin and any other applicable categories of margin) where appropriate:

LCH.C only deals with CMs as principal and is not party to CM/customer arrangements.

  • a.

    Dealer Margin Held Directly at a CM (or at a Custodian Holding Solely for the Benefit of the CM) – If the CM will hold Dealer Margin directly (without a custodian), or the custodian will hold Dealer Margin only for the CM (rather than for customers (individually or as a group)), please detail all aspects of the arrangement that are relevant from a customer protection standpoint, specifically addressing the following:

    • i.

      The manner in which the CM holds the Dealer Margin, distinguishing to the extent applicable between various types of Dealer Margin (e.g., securities or cash), and identifying in particular:

  • 1.

    Whether Dealer Margin securing the positions of a particular CDS customer will be segregated from (i) the Dealer Margin posted by other CDS customers and (ii) the property of other custodial claimants of the CM, or instead, commingled in a single omnibus account (either for CDS customers or custodial claimants of the CM generally);

    • a.

      In whose name(s) has/have the account(s) been established?

  • 2.

    Whether Dealer Margin securing customer positions will be segregated from the margin securing proprietary positions of CMs;

  • 3.

    Any operational practices (whether voluntary or mandated by regulators) relevant to the analysis of customer protection and the sharing of any shortfalls in custodial property;8 and

4. Under what circumstances Dealer Margin may be (i) withdrawn by customers or (ii) applied by CMs or the CCP.

See note 6.


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