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23 October 2017

AFME’s response to European Commission’s proposal for a regulation amending EMIR


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The position paper states that particularly in the domain of OTC derivatives, robust and efficient clearing services enhance the safety of the risk reducing transactions undertaken by real economy corporates and investors.


AFME supports the main elements of the EC Proposal to enhance the supervision of CCPs in the EU and in relevant third countries to foster financial stability and strong competition among CCPs within and beyond the boundaries of the EU. Given the derivatives market’s global nature, this would involve strong cross-border supervisory cooperation. AFME notes that the FSB produced a broad range of approaches to deference which may be helpful in this context2.

AFME considers that regulatory requirements that lead to fragmented, inefficient and expensive markets for real economy corporates and investors should be avoided.

AFME calls for maximum consistency between the Commission’s proposed supervisory reforms and existing proposals on recovery and resolution of CCPs in the EU. Further, given the global character of derivatives clearing, AFME supports alignment with the global standards developed by FSB/CPMI-IOSCO on CCP resilience, recovery planning and resolvability.

AFME supports the European Commission’s objectives of achieving enhanced supervision of CCPs, and of mitigating potential systemic risks in the context of highly integrated global and European financial markets.

AFME considers that, despite the proposed withdrawal of the UK from EU, the most desirable outcome is a situation in which EU and third country CCPs can continue to service integrated global markets, and in which risks associated with such an outcome are managed appropriately and proportionately.

Full position paper



© AFME


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