Nevertheless, we think that the proposed active account scheme is not in line with the objectives of the clearing package, as it does not ultimately make EU clearing more attractive, while in addition may end up not being to the benefit of investors. We therefore present our concerns and highlight the need for a careful assessment of the impact of the proposal for active accounts.

We also take this response as an opportunity to present again our proposed proportionality approach to the exchange of Initial Margins in certain circumstances.  

View theALFI response.