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FIA response to the EMIR Review

FIA response to the EMIR Review

17 August 2015 1:00pm EDT

Last week, FIA submitted its response to the European Commision's EMIR Review. We will be discussing the next stages of our advocacy with our Government Relations Working Group during the next couple of weeks.

FIA’s response focused on key areas members advocated for:

  • ETD reporting: the removal of ETD from the reporting obligation, failing which a move to single-sided (end-of-day) position reporting ;
  • OTC reporting: a move to single-sided transaction reporting;
  • Indirect clearing: indirect clearing to remain voluntary for clearing members to offer. The European Commission should also remove any doubt regarding the potential for conflict between EMIR and member state/third country insolvency and property laws;
  • Frontloading: removal of the frontloading obligation for future assets classes and products;
  • Compression: an exemption from the clearing obligation for trades resulting from compression via a certified portfolio compression service;
  • Clearing Obligation: the ability for regulators to suspend/terminate the clearing obligation;
  • Cross-border: swift completion of the outstanding equivalence assessments and more transparency in the process;
  • Link to CRR: the European Commission to consider delinking EMIR recognition from QCCP status under CRR;
  • Central bank facilities: CCPs to have access to central bank deposit and liquidity facilities at all times, not just in stressed markets;
  • CCP authorisation extension: further clarity as regards the specific circumstances that should trigger the need for a CCP to seek an extension to its EMIR authorisation;
  • NFCs: various changes to the clearing threshold methodology, that third country AIFs be deemed equivalent to non-financial counterparties and that various public/governmental bodies be exempted from EMIR; and
  • CCPs: more skin in the game, greater clearing member input into CCP governance and more consistent rulebooks

Attachments

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FINAL FIA Europe response to the EMIR Review.pdf (633.41 KB)

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