Comment Letter to European Commission on Public Consultation on Derivatives and Market Infrastructures

MFA submitted a comment letter in response to the European Commissions (EC) Consultation Paper on Derivatives and Market Infrastructures. In our letter, MFA applauded the ECs interest in considering differing market perspectives as it finalizes its draft legislative proposals and policies regarding central clearing, improved transparency and other aspects of the OTC derivatives market. In addition, we expressed our general support of: (i) the bottom-up approach to the ECs mandatory clearing obligation; (ii) the general approach specified in the consultation paper on organizational requirements and governance processes for European central counterparties (CCPs); (iii) the ECs rule requiring each clearing member to distinguish and segregate in accounts with the CCP the assets and positions of that clearing member from those of its clients; and (iv) the ECs principle regarding non-cleared OTC derivatives contracts being reported to a trade repository, but expressed concern regarding the options presented in the consultation paper.