The Polish Presidency has now included the word OTC (no longer in brackets throughout the entire text). This means that they want EMIR only to cover OTC derivatives contracts.
Comparing this text with the Council compromise text dated 18 July, a priori, Poland's revised compromise text on EMIR has considerably changed Article 6. The text of Article 6 requires collateral and other risk-mitigating measures on OTC trades that are not processed within clearinghouses. Intragroup transactions can be exempted from those provisions, under certain conditions, such as having robust risk-management procedures. The decision for the exemption would be taken by the relevant authority.
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