On January 27, ISDA responded to the European Securities and Markets Authority’s (ESMA) consultation on the active account requirement (AAR) introduced under the revised European Market Infrastructure Regulation (EMIR 3.0). In the response, ISDA highlighted significant concerns about the proposed reporting regime to monitor compliance with the AAR. The proposal seems to go beyond what is necessary to monitor compliance and is inconsistent with the EU’s recent commitment to reduce administrative and reporting burdens. The response also highlights that some aspects of the operational requirements – in particular, stress testing – are not clear. However, the response welcome the fact that the proposed calibration of interest rate swaps denominated in Polish zloty for the representativeness requirement recognizes that liquidity at EU central counterparties is extremely limited.
Documents (1) for ISDA Response to EMIR Active Account Consultation
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