About this initiative
Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) No 648/2012 as regards the clearing obligation, the suspension of the clearing obligation, the reporting requirements, the risk-mitigation techniques for OTC derivatives contracts not cleared by a central counterparty, the registration and supervision of trade repositories and the requirements for trade repositories
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ABN AMRO Clearing Bank N.V. (Netherlands)
ABN AMRO Clearing Bank N.V. (AACB) wishes to express that it welcomes the opportunity to respond to the European Commission’s proposal (the proposal) amending regulation (EU) No 648/2012 (EMIR). AACB recognises the importance to specifically highlight and respond to a number of changes that have been put forward in the proposal such as: The reporting of ETD's FRAND requirements Protection of client assets at CCPs Reporting of exchange traded...
CME Group (United States)
CME Group welcomes the feedback request from the European Commission (the Commission) proposal for a regulation to amend the European Market Infrastructure Regulation (EMIR) as part of the EMIR review under the Commission’s REFIT programme published on 4 May 2017 (the Final Report). Many of the Commission’s proposals in the Final Report reflect comments previously submitted by CME Group and other derivatives industry organisations as part of...
ISDA welcomes efforts to refine EMIR. However we believe the framework could be further enhanced: • Amendments to definition of financial counterparty (FC): These will have unintended (for AIFs) and/or disproportionate and damaging (for SSPEs) consequences. We urge reconsideration. • Exemptions: o Transactions with EU, non-EU central banks, DMOs and MDBs should be exempt from EMIR, consistent with other G20 jurisdictions and reflecting the...
EDF welcomes the EU Commission’s proposal for a Regulation amending EU Regulation 648/2012 (EMIR) as far as it stipulates a simplified and improved framework to meet the objectives in a more proportionate, effective and efficient manner. In particular regarding provisions for non financial counterparties (NFC), EDF supports the retention of the so-called “hedging exemption” in the calculation of the clearing threshold and the removal of the...
Citadel LLC (United States)
Citadel LLC (“Citadel”) appreciates the opportunity to provide comments to the European Commission (the “Commission”) on the proposal to further refine and enhance the European Market Infrastructure Regulation (the “EMIR Refit” proposal). EMIR implements several of the G20 commitments to improve the safety, stability and transparency of the OTC derivatives markets, including (a) central clearing, (b) transaction reporting to trade repositories...
Energy UK (United Kingdom)
Energy UK broadly welcomes the changes proposed in the Commission’s draft revision of EMIR. These should reduce unnecessary burdens on non-financial counterparties (NFCs), while ensuring that regulators can maintain effective oversight of OTC derivative markets. Beneficial changes include the following: Simplification of provisions relating to the clearing threshold and obligation, and removal of the “breach-one-breach-all” criterion; ...