Should the price field at position level be amended following a change in the notional amount?

(a) For the purpose of reporting under EMIR REFIT, how should OTC accumulator contracts – i.e., derivative contracts in which the buyer enters into an agreement to purchasing a predetermined number of underlying financial instruments at a predefined price, per day - over a specified ‘accumulation’ period, be classified?


(b) How should these contracts be reported under EMIR REFIT?

What is the seniority between the own funds and the insurance policy in case of losses for the CSP whose prudential safeguards are a combination of own funds and insurance policy (as allowed in point (c) of Article 11(2) of the ECSPR)?

What should be done with a possible own risk excess of the insurance policy that CSPs subscribe to comply with the prudential safeguards established under Article 11 of the ECSPR?

Are all CSPs that facilitate granting loans required to have a risk management framework? Shall such a framework be based on risk categories for the loans offered by the CSP?