(a) How should accumulators - i.e. derivative contracts whereby the buyer commits to buy a predefined number of underlying financial instruments at a predefined price, per day, over a certain “accumulation” period - be classified?

(b) Should the IF report the single transactions executed when settling the accumulator contract?

(c) Should the IF report the transactions concluded with third parties to secure the financial instruments to be sold to the accumulator’s buyer?

(d) How should the accumulator contract be reported?

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?