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Questionnaire for CDS CCPs on Protection of Customer Initial Margin - page 4 / 32

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9. Please detail any legal or regulatory segregation requirements applicable to customer IM held at the custodians.

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

Structure of the Customers

  • 10.

    Please describe the legal structures applicable to the customers

    • a.

      Does the CCP restrict either the (i) organizational type or (ii) jurisdictions of organization of customers? (Note: This may be important, as some of the legal analysis may depend on the insolvency laws applicable to the customers.)

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

11. Please list all relevant regulatory and supervisory authorities applicable to the customers.

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

Expansion/Restriction of Permitted Entity Types

12. In weighing the relative benefits and drawbacks of expanding or restricting the entity types and jurisdictions of the CMs, customers and custodians, what factors did the CCP consider in its analysis? For example, to what extent did the CCP consider the following issues in reaching its proposed structure?

A variety of factors are considered, depending on the service and product in question.

a. Netting implications for CMs and their affiliates (from a credit, accounting and capital perspective);

  • b.

    Regulatory capital implications for CMs and their affiliates;

  • c.

    Operational efficiencies or inefficiencies, and other business implications

of operating through the permitted entity types;

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