EACT comments in response to ESMA consultation paper: Draft Technical Standards for the Regulation on OTC Derivatives, CCPs and TRs
06 August 2012
The comments reflect the perspective of the classic role of the corporate treasurer, which is to use financial instruments such as derivatives to mitigate rather than to take on risk.
The EACT welcomes the work done by ESMA to develop the draft technical standards covered by this consultation paper. In the aim of providing the most constructive support to ESMA, EACT is limiting its comments to the areas of most concern in the drafting. In all cases, the views it expresses are done so from the position of non-financial counterparties, in other words the real economy end-users of the financial system.
The comments on ESMA’s drafting can be grouped under the following headings:
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definition of hedging;
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clearing thresholds;
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administration requirements – risk mitigation techniques; and
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reporting to trade repositories.
Full comment letter
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