Vanguard appreciates the opportunity to provide comments to the European Commission’s proposal (the "CCP Proposal') to amend EMIR in relation to the supervision of European Union (“EU”) and third-country clearing houses (“CCPs”). Vanguard supports the stated goals of the CCP Proposal to ensure that EU supervisors are able to appropriately oversee CCPs that clear products for EU investors. However, Vanguard is of the firm belief that such oversight must be exercised in a manner that preserves market liquidity and avoids market fragmentation that could negatively impact investors and, especially, EU investors. Please see the attached comment letter for detailed recommendations.
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