EFTA Document EFTA01377178

DRAFT - FOR DISCUSSION - February 15, 2017 • Threshold and Minimum Transfer Amount (MTA): A margin rule compliant VM CSA must reflect a threshold of zero, meaning that any mark-to-market exposure must be collected in the form of VM, subject to the applicable MTA. The margin rules cap the MTA at $500,000 (which also covers initial margin, if any). Deutsche Bank's preference, however, is to apply an MTA of $250,000. • Eligible collateral: In general, eligible collateral for a margin rule c