[ESMA 35-36-1262 Q&As on product intervention Q&A nr 5.2]

The definition of initial margin in the CFD Decision refers to payments for the purpose of entering into a CFD, excluding commission, transaction fees, and any other related costs. Payment for the purpose of entering into a CFD is limited to cash.

“Payments“ do not include firms crediting cash to the client’s account based on collateralised cash from other assets, held by the retail client being used as collateral, whether such assets are within or separate to the CFD trading account.