On September 4, ISDA, the European Fund and Asset Management Association (EFAMA) and FIA shared a paper with EU policymakers requesting clarification on the implementation of the active account requirement under the third European Market Infrastructure Regulation in relation to representativeness. In particular, the paper addresses the frequency required to determine the most relevant subcategories, the treatment of counterparties falling below the €6 billion threshold and reporting considerations for representativeness.
Documents (1) for ISDA, EFAMA, FIA Submit Paper on EMIR 3 Active Account Representativeness
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