17 August 2015

欧州保険連盟、EMIR（欧州市場インフラ規則）に関する欧州委員会の市中協議へコメント、年金や保険等の長期投資家が現金以外の担保を清算機関に移管するケースは少ない点を指摘

Therefore, Insurance Europe believes that there are two possible solutions to address the concern of cash:

• Consider a permanent exemption from the central clearing obligation for both pension funds and insurance companies that use derivatives for hedging.
• Encourage central counterparties (CCPs) to develop tailored solutions for both pension funds and insurance companies, allowing for non-cash collateral as variation margin.

Other key messages are:

• It should be clarified that European Market Infrastructure Regulation (EMIR) does not apply to insurance products.
• The obligation for dual-sided reporting (DSR) should be removed and replaced by a requirement for one-sided reporting.
• The obligation to backload closed trades is costly and operationally cumbersome, while adding little value to the effectiveness of the EMIR regulatory regime.
• The delays in the finalisation of implementation rules for EMIR and lack of clarity around requirements have  led  to  market  players  making  assumptions  and  proceeding under  uncertainty ,  and  resulted  in planning  issues  for the insurers concerned due  to unclear  timescales  and a lack  of  formal commitments.

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