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Further amendments to the European Market Infrastructure Regulation (EMIR)

Banking and financial services

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Public consultation

ID: 1400

Lobbying Activity

13 responses

Consultation response

BlackRock, 17 Jul 2017

Implications of a location policy on end-investors The Commission has proposed a two tier approach to supervision of CCPs under the EMIR 2.0 proposals. We are encouraged that these do not include automatic relocation triggers for Euro-clearing – but there are provisions for ESMA and the ECB to…

Consultation response

Deutsche Börse AG, 30 Oct 2017

Following the financial crisis the G20 committed to global goals bringing OTC markets towards more transparency. For CCPs in particular the G20 commitment led CCPs to become the neutral and trusted risk managers of financial markets. We highly appreciate European Regulators have taken their…

Consultation response

Bundesverband Öffentlicher Banken Deutschlands eV, 30 Oct 2017

We support the Commission's proposal of generally tightening the regulatory regime for central counterparties (CCPs) domiciled in third countries. Unless the EU and the United Kingdom are able to agree upon appropriate supervisory practices, it might also be necessary to require CCPs that are…

Consultation response

London Stock Exchange Group, 30 Oct 2017

LSEG welcomes the opportunity to respond to the European Commission legislative proposal amending EMIR relating to the supervision of EU and third-country CCPs, leveraging from its experience supporting the operations of the CCPs of the Group in Italy, France and the UK. Please see the feedback…

Consultation response

AMUNDI AM, 27 Jul 2017

1. Third country CCPs : Amundi supports the classification of CCPs according to their level of systemic risk and the enhanced supervisory role of the central bank which ensures final liquidity. Amundi also agrees that equivalence for CCPs of third countries should be a continuous process and that…

Consultation response

European Federation of Investors and Financial Services Users, 30 Oct 2017

BETTER FINANCE, the European Federation of Investors and Financial Services Users, welcomes the opportunity to comment on the Commission’s proposed regulation as regards the procedures and authorities involved for the authorization of CCPs (central counterparties) and requirements for the…

Consultation response

International Swaps and Derivatives Association, 5 Oct 2017

ISDA’s response to the Commission’s proposed regulation as regards the procedures and authorities involved for the authorisation of CCPs and requirements for the recognition of third-country CCPs (the “EC Proposal”) ISDA and its members welcome the European Union’s review of CCP supervision…

Consultation response

The Alternative Investment Management Association Limited, 21 Sept 2017

Please find attached the comments of the Alternative Investment Management Association regarding these proposals.

Consultation response

The Investment Association, 8 Sept 2017

Executive Summary The Investment Association (’The IA’) thanks the European Commission for the opportunity to respond to the Proposal of 13 June 2017 as regards the procedures and authorities involved for the authorisation of CCPs and requirements for the recognition of third-country CCPs (‘The…

Consultation response

Futures Industry Association, Inc., 7 Sept 2017

FIA supports the European Commission's commitment to ensuring that third-country CCPs are appropriately supervised as part of a well-regulated central clearing system. We set out below a number of positive recommendations to further enhance the changes proposed by the Commission with respect to…

Consultation response

European Association of Central Counterparty Clearing Houses, 30 Oct 2017

IIn the experience of EACH Members, the current system of supervision of EU CCPs through the EMIR college architecture functions generally quite well. It represents an innovative system of supervision that aims to match the benefits of regulatory convergence and local knowledge. While EACH agrees…

Consultation response

CME Group, 30 Oct 2017

Please see attached letter.

Consultation response

Global Financial Markets Association, 30 Oct 2017

Dear Sirs or Madams, The Global Financial Markets Association (GFMA) thanks the European Commission for the opportunity to respond to the proposal of 13 June 2017 regarding the procedures and authorities involved for the authorization of Central Counterparties (CCPs) and requirements for the…