MFA Updated Response on Proposed Regulation on OTC Derivatives, Central Counterparties and Trade Repositories

MFA updated its response to the European Commission’s 2010 Proposal for a Regulation of the European Parliament and of the Council on OTC Derivatives, Central Counterparties and Trade Repositories (EMIR) to reflect MFA’s views on changes made to EMIR as set forth in separate draft texts of the European Parliament and the Council of the European Union. MFA continues to support efforts to promote central clearing and thereby: (i) increase transparency of the derivatives market; (ii) reduce counterparty and operational risk in trading; and (iii) enhance market integrity and oversight. Therefore, these updated views are intended to assist the European Commission in developing further legislative refinements to EMIR, in particular, as they relate to the following issues: (1)Governance of central counterparties; (2)Portability of client positions and assets; (3)Portfolio margining and netting; (4)Real-time clearing; and (5)Segregation of collateral at central counterparties.

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