Article 18(2), first subparagraph, point (e) of Regulation (EU) 2015/760, as amended, sets out that the rules or instruments of incorporation of an ELTIF may provide for the possibility of redemptions during the life of the ELTIF provided that […] the redemption policy of the ELTIF ensures that investors are treated fairly and redemptions are granted on a pro rata basis provided some conditions are met. Recital (48) of Regulation (EU) 2015/760, as amended, details the conditions that may distinguish share classes (fees, legal structure, marketing rules) but also includes “other requirements” but provides no further details on the nature of such “other requirements”.

Should the words “other requirements” be interpreted as allowing for the use of (a) different notice periods, (b) different redemption gates and/or (c) different redemption frequency for different classes of units or shares of ELTIFs?

We would appreciate to clarify the two issues referred below in the context of the calibration of the confidence interval for CCP margin requirements.

Q1. Article 24(1) of Commission Delegated Regulation (EU) No 153/2013 (RTS on CCP requirements) sets out the minimum confidence intervals for the calculation of the initial margins of a CCP to 99,5% for OTC derivatives and 99% for financial instruments other than OTC derivatives. Can a CCP rely on the back testing performance of its margin model as sole proof of compliance with Article 41 of EMIR and Article 24 of the RTS on CCP requirements?

Q2. If a margin model has several components, does each component need to be calibrated to the confidence interval set out under Article 24 of the RTS on CCP requirements?

Is a DLT MI (digital ledger technology market infrastructure) operator allowed to provide MiCA crypto-asset services such as operating a trading platform and custody services for emoney tokens without an additional MiCA licence?

What are the capital requirements for a DLT TSS (digital ledger technology trading and settlement system) operated by: a) an investment firm; b) a credit institution; c) a CSD (central securities depository)?

Can subscription rights be covered under the DLTR?