PensionsEurope welcomes the opportunity to comment on the EBA consultation about its draft Regulatory Technical Standards (RTS) on Initial Margin Model Validation (IMMV) under the European Markets Infrastructure Regulation (EMIR).

We therefore suggest removing the article 2, 2. option or, at least, to provide clearer and more objective criteria for requiring section 3 compliance from counterparties above the EUR 50 billion threshold. You can read our comments here.