FIA jointly with ISDA has submitted its response to the Bank of England’s proposed approach to tiering under UK EMIR 2.2. Overall, the associations support the spirit and goals of the BoE’s approach to regulatory deference and cooperation and welcome its aims to put them at the centre of its approach.
The associations’ members have long advocated that the most optimal way to manage financial stability risks is to have supervisory and regulatory cooperation, working together, and making sure that authorities have the information they need to protect the markets that benefit all participants and the real economy.
Many members of the associations believe that the BoE’s approach focuses successfully on regulatory deference and cooperation and is designed to create a more optimal way of approaching third-country CCP oversight in a holistic and proportionate manner. However, a concern for some members is, among other things, that incoming CCPs may be inappropriately categorised as Tier 2 CCPs, which is in contrast to the EU’s approach where they would fall into a Tier 1 category.
Read the full response.
