According to new Article 50a of EMIR a CCP shall calculate the hypothetical capital (KCCP) as follows: KCCP = (Σimax{EBRMi – IMi – DFi;0} · RW · capital ratio) where: EBRMi = exposure value before risk mitigation that is equal to the exposure value of the CCP to clearing member i arising from all the contracts and transactions with that clearing member, calculated without taking into account the collateral posted by that clearing member; IMi = the initial margin posted to the CCP by clearing member i; DFi = the pre-funded contribution of clearing member i; RW = a risk weight of 20 %; capital ratio = 8 %. The above means that CCP, while calculating the EBRMi shall add exposure value of the CCP to clearing member i arising from all the contracts and transactions with that clearing member, calculated without taking into account the collateral posted by that clearing member; However, according to Article 50b(a)(ii), establishing the general rules for calculation of the hypothetical capital: for exposures arising from contracts and transactions listed in Article 301(1)(b), (c) and (e) of Regulation (EU) No 575/2013 shall calculate them in accordance with the Financial Collateral Comprehensive Method specified in Article 223 of that Regulation with supervisory volatility adjustments, specified in Articles 223 and 224 of that Regulation. According to Article 223(5) of CRR fully adjusted value of the exposure (E*) shall be calculated taking into account both volatility and the risk-mitigating effects of collateral as follows: E* = (max {0, EVA – CVAM}) where: EVA = the volatility adjusted value of the exposure as calculated in paragraph 3; CVAM = CVA further adjusted for any maturity mismatch in accordance with the provisions of Section 5; CVA is the volatility-adjusted value of the collateral calculated according to Article 223(2) of CRR. In consequence, a CCP, while calculating exposure value for all types of contracts mentioned in new Article 50b(a)(ii) of EMIR, has to calculate it using Financial Collateral Comprehensive Method specified in Article 223. This Method implies that the collateral value shall be deducted from the exposure value, taking into account both volatility and the risk-mitigating effects of collateral. Moreover, according to Article 50b(c) of EMIR, when calculating the value of the exposures, the CCP shall subtract from its exposures the collateral posted by its clearing members, appropriately reduced by the supervisory volatility adjustments in accordance with the Financial Collateral Comprehensive Method specified in Article 224 of Regulation (EU) No 575/2013. To sum up, CRR does not clearly specify what value should be substituted for EBRMi.