Portfolio Compression. 9.1 ODPs are required to perform portfolio compression, whether bilateral or multilateral portfolio compression, at least twice annually where appropriate and technologically possible. Where a portfolio compression is deemed appropriate, the Company has procedures designed to ensure that it -(a) regularly, but at least twice a year, analyze the possibility of conducting a bilateral or multilateral portfolio compression exercise, where appropriate and technologically possible, in respect of 500 or more non-centrally cleared open OTC derivative transactions with other providers; and (b) terminates fully offsetting non-centrally cleared open OTC derivative transactions with its counterparties and clients. 9.2 The Company will maintain a complete and accurate record of each bilateral offset and each bilateral or multilateral portfolio compression exercise in which it participates. The Company will also ensure that it is able to provide a reasonable and valid explanation to the FSCA for concluding that a portfolio compression exercise is not appropriate.
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Sources: Client Agreement, Client Agreement