About this initiative

Banking and financial services
Type of act
Delegated regulation

Draft act

Feedback: closed

Draft delegated regulation
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Feedback period
31 October 2016 - 28 November 2016 (midnight Brussels time)
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Download (178.7 KB - PDF - 6 pages)

Feedback (6)

  • International Swaps and Derivatives Association (United States)
    28 November 2016 Business association
    International Swaps and Derivatives Association (United States)

    The International Swaps and Derivatives Association ("ISDA") welcomes the opportunity to provide feedback on amending Regulation (EU) No 648/2012 ("EMIR") of the European Parliament and of the Council as regards the extension of the transitional periods related to pension scheme arrangements ("PSAs"). We strongly support the overarching goal of reducing systemic risk in the OTC derivatives market and the central clearing of certain classes of...

  • The Investment Association (United Kingdom)
    28 November 2016 Business association
    The Investment Association (United Kingdom)

    The Investment Association supports the proposal to extend the pension funds exemption from central clearing by a further year. As CCPs continue to demand only cash VM, the argument by which PSAs were originally exempted from the clearing obligation still stands. It is not in the interests of financial stability or the end client to expect PSAs to post only cash VM. The Commission’s report of 3 February 2015 on Article 89 conceded that it...

  • PensionsEurope (Belgium)
    22 November 2016 Business association
    PensionsEurope (Belgium)

    This feedback was removed either at the request of the author or because it did not comply with the European Commission's rules for publishing feedback and suggestions.

All feedback (6) >

Commission adoption


Delegated regulation
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