The Following main points were presented in the IMF position paper:
· The reform proposals should be internationally coherent, in order to reduce the risk of disjointed policies, distorted capital flows and regulatory arbitrage.
· Moving OTC derivatives contracts to CCPs will bring high transition costs due to the need to post large amounts of additional collateral at the CCPs.
· If approved, mandatory central clearing for OTC derivatives should be phased in gradually.
· IMF supports some exemptions for end-users that are involved in “real” hedging transactions.
· IMF supports the threshold but calls on the Commission to clarify what exactly will be the threshold.
© International Monetary Fund
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