AFG has published its response to the European Commission’s EMIR 3.0 proposal.
We highly welcome the Commission’s EMIR 3.0 package proposal which aims to enhance the well functioning of the central clearing framework and to reduce excessive exposure to substantially systemic clearing services of third country CCPs. We particularly appreciate the improvement of the CCPs regulatory framework on margin transparency which by the way should not only call on clearing members but also oblige CCPs to contribute and the clarifications on transaction exemptions. We fully support as well ESMA’s approach of distinguishing cleared and uncleared derivatives products rather than between OTCDs and ETDs. We are fully committed to support efficient and proportionate measures strengthening EU Capital Markets autonomy and safeguard financial stability.
With this in mind, we are nevertheless concerned by the current design of active accounts under the proposal as long as sufficient information on its effective implementation is not available. We are particularly concerned with the risks of unintended negative consequences it could bear for EU Capital Market participants and investors for several reasons developed in our position paper.
