Application of a cash deposit and hedging contract on CFDs in order to reduce market risk capital requirements

Can the financial contract described below be applied for reducing or netting market risk capital requirements of business with CFDs?

For a bank’s proprietary trading of CFDs (comprising risk classes FX, equity, commodity) with clients open positions are taken on the trading book. The resulting market risk is intended to be hedged by a contract with a counterparty (protection seller).This contract is based on ISDA rules and connected to a corresponding cash account. Potential losses within the banks CFD portfolio (net market value changes) are offset by cash of that account up to an agreed amount. There is no distinct allocation of the funds to the separate risk categories (FX, commodity, equity) causing the value changes of the banks CFD-portfolio.   Can the arrangement be applied in order to reduce equity risk (specific risk), FX-risk and commodity risk (net position) when calculating capital requirements for market risk standardised approach? With respect to CFDs on equities or commodities may the hedge arrangement considered an “identical” financial instrument capable of being netted against the CFDs it references?