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?

Should a credit institution authorised in accordance with CRD IV/CRR and providing investment services or performing investment
activities in accordance with MiFID II/MiFIR be required to apply for an authorisation as an investment firm in order to operate a DLT MTF (distributed ledger technology multilateral trading facility)?