The proposal goes well beyond what was agreed by the Council of Ministers and the European Parliament when they agreed the Derivatives Regulation, and undermines the purpose of the temporary exemption from the clearing obligation that they provided for pension schemes. The NAPF argues in its response that adequate and properly controlled variation margin is more than sufficient to provide protection against the risks to individual institutions and to systemic stability about which the supervisory authorities are concerned.
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© NAPF - National Association of Pension Funds
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