ABN AMRO Clearing Bank N.V.
AACB
ABN AMRO Clearing Bank N.V.
ID: 368029129221-78
Lobbying Activity
Meeting with Wopke Hoekstra (Commissioner) and
21 Jan 2026 · Battery Industry Development and Strategic Challenges
Meeting with Auke Zijlstra (Member of the European Parliament)
15 Jan 2026 · Market Integration Package
Meeting with Dirk Gotink (Member of the European Parliament) and Optiver and Cboe Clear Europe N.V.
27 Jun 2025 · Capital markets
Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and Euronext and
30 Jan 2024 · IFR-IFD, Europe’s capital markets
Meeting with Joost Korte (Director-General Employment, Social Affairs and Inclusion) and Vereniging VNO-NCW and
24 May 2023 · EU social policy making, European Pillar of Social Rights and future initiatives
Meeting with Erik Poulsen (Member of the European Parliament, Shadow rapporteur) and Cboe Clear Europe N.V.
13 Apr 2023 · EMIR
Meeting with Mairead McGuinness (Commissioner) and
21 Sept 2022 · Energy derivatives market
Meeting with Esther De Lange (Member of the European Parliament)
21 Sept 2022 · Introductory meeting - APA
Meeting with Michiel Hoogeveen (Member of the European Parliament, Committee chair)
15 Oct 2021 · ECON committee
13 Apr 2021
(response also submitted as pfd)
Response to the consultation on the delegated act extending the clearing exemption for pension scheme arrangements
ABN AMRO Clearing Bank N.V. (AACB) welcomes the opportunity to comment on the proposed delegated act that extends the clearing exemption for pension scheme arrangements (PSAs) with one year. AACB has been an outspoken supporter of central clearing, and welcomes the improvements that have been made in the past 10 years. Central clearing has been key in the reduction of risk in the financial sector in the aftermath of the financial crisis and remains a cornerstone of safe and transparent markets.
We believe that the extension of the clearing obligation to PSAs would further strengthen the resilience and transparency of financial markets. However, we agree that the entry into force of this obligation should be subject to regulatory and market improvements, enabling market participants to develop appropriate technical solutions within this period. At present a few constraints are hindering both clearing members and PSAs to support the clearing obligation for PSAs. For clearing members this includes the impact on their balance sheets, their regulatory liquidity constraints and their constraints to continuously access central bank liquidity facilities. For PSAs the key constraint appears to be the requirement to keep sufficient cash buffers (liquid resources) available to meet CCP variation margin calls, resulting in increased credit risk on banks to store cash and reduced investment performance. We have explained these issues in more detail in our response to the ESMA consultation paper on this matter. Another constraint for European institutions is the limited opening hours of Target2. We believe that accelerating the planned extension of the Target2-opening hours would be very helpful to European firms, since they would not have to resort to non-euro liquidity to comply with CCP margin requirements.
As these issues are not yet resolved, we understand the need for an extension of the clearing obligation for PSAs. However, we would again underscore the importance of safe and transparent markets, and the need for PSAs to contribute to a resilient infrastructure. This has become even more important with the current debate regarding the location of clearing of interest rate swaps. We believe that building up liquidity on the continent will become attainable if we were to exploit the potential synergies between the post-Brexit priorities and the implementation of the clearing obligation for PSAs. Implementing the clearing obligation for PSAs could bring significant liquidity to European CCPs, as they potentially have the offering best adapted to deal with PSA’s objections. In addition, it would also attract non-EU financial institutions to the continent. Of course this should go hand in hand with finding solutions to the constraints identified above.
Thank you again for the opportunity to contribute to this important debate. We welcome any questions you may have regarding our position.
Read full responseMeeting with Maarten Verwey (Director-General Economic and Financial Affairs)
25 Sept 2020 · Meeting with CEO of ABN AMRO
Response to Carbon Border Adjustment Mechanism
31 Mar 2020
ABN AMRO Clearing Bank (AACB) is a longstanding supporter of the energy transition and has been facilitating the cap and trade system since the introduction. We clearly see the benefits of the current Emissions Trading System, including the strong policy commitment, the effective price formation on the markets as a function of supply and demand, and the increasing certainty that emissions will fall below a predetermined emissions target because of the emission cap decline. In addition, the EU ETS has contributed to a significant increase in awareness about the environmental cost of carbon emissions.
However, we feel, in line with the Inception Impact Assessment, that a few improvements could be considered.
A further extension of the scope of the EU would significantly improve the effectiveness of the system. Starting with energy-intensive industries (e.g. steel, cement, chemicals etc.) for piloting purposes and then applying it to all other sectors will be key for prudent expansion of the EU ETS. We estimate that, given a balanced allocation of new carbon rights, this could boost price formation and the impact on the real economy.
Carbon leakage could, consistently with the direction of thinking of the European Commission, be a threat to the European ambitions regarding climate change and could unintentionally hamper EU production. A carbon border adjustment mechanism, with the appropriate design, could solve this problem. AACB feels that a new carbon customs duty, complementary to the EU ETS would be the most sensible approach. However, we would like to stress that it is of utmost importance that the methodology of such an import duty is designed carefully, technically feasible, and does not unnecessarily hamper EU economic performance.
Few considerations/improvements that are important to note:
1 The volatile price of EU ETS, especially in the early days, has limited the effectiveness of EU ETS in reducing the CO2 emissions in Europe as it could not provide full investment certainty. This price volatility has been driven by not only the policy reforms, but also fuel prices, Europe-wide heatwaves, the trading strategies of large generators, and the active management of EUAs by small industry players. For example, with this price volatility, a price floor, both on the EU ETS and the new carbon duty, can provide investment certainty although it does not necessarily result in further emission savings.
2 National policies of member states also contributed to the price evolution of EUAs and its effectiveness. Tightening the ETS cap has proven to be effective in helping phase out some of the fossil fuels but national policy is important to complement EU ETS to incentivise low carbon build-out. A successful expansion of the scope of the EU ETS is conditional on a balanced allocation of new carbon rights.
3 Auctioning versus free allocation is another important feature of the EU ETS market mechanism. Sectors’ benchmarks calculation can allow a comparative analysis between different importers and as such a fair allocation of emission credits while limiting any surplus accumulation or pass through behavior. In addition, a continuous update of the system of free allocation to focus on sectors at highest risk of carbon leakage will be crucial.
4 Having an infrastructure to monitor, report and verify emissions from different parts of the supply chain is crucial for proper allocation of credits and penalization in case of non-compliance.
The European Commission is taking a major step to design a working Carbon Border Adjustment Mechanism to create a level playing field for all producers by exposing them to similar emission reduction requirements. However, it remains crucial that the EU takes into account the risk of carbon leakage, the vulnerability and data reliability of some developing countries, the EU ETS price volatility and investment certainty, the allocation of emission credits, etc.
Read full responseResponse to Extension of transitional period on own funds requirements for exposures to central counterparties
18 Apr 2018
ABN AMRO Clearing Bank N.V. (AACB) welcomes the Commission Implementing Regulation (Draft implementing regulation) from 17 April 2018 that would extend the transitional periods related to own funds requirements for exposures to central counterparties (CCPs) as set out in Regulation (EU) No 575/2013 (“CRR”) and (EU) No 648/2012 (“EMIR”). The current transitional periods expires on 15 June 2018. The proposed Draft Implementing regulation would extend the transitional period to 15 December 2018.
As AACB mentioned in its numerous responses to previous extensions of the transitional period, it appreciates the fact that the equivalence assessments with a large number of jurisdictions have been finalised. AACB would be heavily affected in case the transitional periods for the recognition of third-country CCPs is not extended. For AACB, this will lead to significant increase in the amount of capital AACB is required to hold with respect to exposures to third-country CCPs. Moreover, AACB agrees with the concerns expressed in the Draft Implementing regulation that markets could be seriously disrupted if the transitional period as provided in Article 1 of the proposed Draft implementing regulation is not extended.
At the same time, AACB is still concerned about a perceived lack of progress in the equivalence process with the United States of America. An agreement has not yet been reached between the European Commission (EC) and Securities and Exchange Commission (SEC). The SEC is responsible for oversight and supervision of, amongst other self-regulatory organizations, the Depository Trust & Clearing Corporation (DTCC) and the Options Clearing Corporation (OCC).
AACB is one of the largest General Clearing Members on the OCC, clearing for a large number of market makers and liquidity providers on the markets cleared by OCC. Therefore AACB is particularly concerned that the OCC is not yet recognised as Qualifying central counterparty (QCCP). AACB and its clients are concerned that the consequence of exposure to a Non Qualifying CCP (N-QCCP) is a significantly higher risk weighting (RWA) based on trade and default fund exposure. If the OCC is not able to obtain the status of QCCP, trade exposure to the OCC alone will lead to billions of additional RWA and, ultimately, cause a wind-down of the AACB activities on this CCP. As a result, the liquidity provision activities of a large number of market makers that are active on the markets cleared by the OCC will be significantly constrained.
In summary, AACB requests and strongly supports an extension of the QCPP transitional period to 15 December 2018. This extension will enable a thorough assessment of the jurisdictions that remain subject to an equivalence determination. AACB is of opinion that an agreement with the SEC is necessary to avoid unintended material effects/consequences on AACB and its clients based on their exposure to the OCC. At the same time, we kindly request to the European Commission, ESMA and the SEC to conclude equivalence assessments as a matter of priority.
Read full responseResponse to Review of the appropriate prudential treatment for investment firms
27 Feb 2018
ABN AMRO Clearing Bank N.V. (AACB), has taken note of the European Commission (EC) proposal for a regulation on the prudential requirements of investment firms.
AACB is the global top-3 provider of clearing and financing services for listed derivatives, cash securities, warrants, commodities and FX. AACB covers the full market chain from market access and execution services to clearing, settlement and multiproduct asset servicing on a global basis. Our client base includes the majority of the market making and liquidity providing sector, as well as their global peers. The history of AACB is closely linked with the liquidity providing community that started at the Amsterdam Options Exchange and evolved into a mutually leading global role for both AACB’s operations and its clients. AACB plays a key part in the safety and soundness of their activities based on the guarantees it provides combined with its sophisticated risk model that serves as the main proxy for the capital requirements for some of the largest market makers and liquidity providers trading with proprietary capital in the European Union (EU).
As part of the Capital Markets Union and Better Regulation agenda, it was the clear intention of the EC to draft a new tailored and fit-for-purpose capital regime for investment firms in order to have a more proportionate regime compared to the framework under the Capital Requirements Directive (CRD) and Capital Requirements Regulation (CRR). We are grateful for the work that the European Banking Authority (EBA) and the EC have undertaken to define the outline of this new regime. AACB welcomes the simplification and the K-factor approach in comparison with the existing CRD/CRR framework. We strongly believe the new regime provides a more meaningful capital and risk mitigation framework tailored for investment firms, which will decrease their existing burden.
At the same time, AACB is concerned about two specific provisions related to the proposed K-Factors on Market Risk (K-RtM) and Risk to Firm (RtF). As a result of these two provisions, AACB believes dealers on own account providing liquidity on the European markets will be confronted with a significant increase in capital requirements based on the suggested approach by the EC. Furthermore, we believe the RtF K-factor based on the Daily Trading Flow (DTF) is fundamentally flawed as a metric for RtF; it will effectively constitute a penalty on hedging transactions and will not provide an accurate reflection of (operational) risks affecting investment firms dealing on own account.
In general, we believe the proposal could likely prompt European trading firms to reduce their activities on European markets or move their activities/holding companies to other locations. This will impact liquidity on the European markets, as well as a diverse and competitive trading landscape consisting of a fair combination of banks, proprietary traders, retail investors and institutional investors.
Additional details on our concerns can be found in the attached document.
Read full response