ISDA-AFME commentary on indirect clearing under the EMIR – 29 July 2011

The International Swaps and Derivatives Association, Inc.1 (“ISDA”) is pleased to have the opportunity to comment on the European Market Infrastructure Regulation (“EMIR”), the proposed EU Commission regulation on OTC derivatives, central counterparties and trade repositories.  ISDA is writing this letter to explain and emphasise the importance of EMIR having sufficient flexibility so as to accommodate indirect clearing and provide scope for guidance and practice from the European Securities and Market Authority (“ESMA”) in due course.

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Documents (1) for ISDA-AFME commentary on indirect clearing under the EMIR – 29 July 2011

ISDA response to ESMA MiFIR Review Consultation

On July 11, ISDA submitted a response to the European Securities and Markets Authority's (ESMA) fourth package of Level 2 consultation under the Markets in Financial Instruments Regulation Review (MiFIR), on transparency for derivatives, package orders and input/output data for...