Review of the European Market Infrastructure Regulation and accompanying changes to other Regulation and Directives (EMIR/CRR/MMFR and UCITD/CRD/IFD)
The European Banking Federation (EBF) welcomes the legislative package set forth in the communication by the European Commission “A path towards a stronger EU clearing system’’ of December 7th, 2022 to support the development of a better integrated and more attractive clearing landscape in the EU.
In the proposal, the Commission has taken important positive steps to achieve such objectives, including the removal of equivalence as a pre-condition to the availability of the intragroup transaction exemption and the streamlining EU CCPs supervisory procedures for launching new products and model changes.
At the same time, against this background, EBF members emphasize that the proposal also features substantial and highly complex elements, which, if incorrectly and inappropriately addressed, may lead to unforeseen and extensively adverse effects on the competitiveness, resilience and attractiveness of European financial markets and their financial institutions.
Hence, with a view to ensuring the highest quality in legislative outcome and to promote a comprehensive and thorough discussion that may be as evidence-based as possible on the reform of EMIR rules and other critical pieces of regulation going forward, EBF experts the following key observations.
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