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15 June 2020

EFAMA’s REPLY TO ESMA’s CONSULTATION PAPER ON POST TRADE RISK REDUCTION SERVICES WITH REGARDS TO THE CLEARING OBLIGATION (EMIR Article 85(3a

General comments
- Asset managers and funds are rarely benefiting from post trade risk reduction (“PTRR”) techniques, as:
o Our volume of transaction by counterparty is below mandatory compression,
o Our transactions with each counterparty are directional (i.e. one strategy...

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