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IIROC Staff Consultation –Concept Paper on the Feasibility of Portfolio Margining
Letter Summary:
We note that to the extent a new margining methodology could result in excessive leverage, the negative consequences of a severe market downturn on retail clients cannot be overstated. The CAC wishes to respond to the questions in Appendix 1 to the Concept Paper that relate to the use of portfolio margining for determining margin lending limits for certain sophisticated clients as set out below.
Overview of the Council’s Comments:
The Canadian Advocacy Council1for Canadian CFA Institute2Societies (the CAC) appreciates the opportunity to comment on IIROC’s Concept Paper on the Feasibility of Portfolio Margining asset out in IIROC Notice #12-0275.