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EMIR- how was it for you?

The EC has published a consultation seeking input on the implementation of, and “user-experience” to date with  EMIR- providing input into the Commission’s broader review of the regulation.The custom questionnaire may be found here. A public hearing will be held at the Commission’s offices in Brussels on 29 May 2015. The deadline for comments and form submission is 12 August 2015.

The 13 page document solicits feedback on the following EMIR topics:

  • CCP Liquidity
  • Systemic importance of Non-Financial Firms
  • CCP Colleges
  • Procyclicality
  • CCP Margins and Collateral
  • Clearing Obligation
  • Risk Mitigation Techniques
  • Exchange of Collateral
  • OTC Cross-border activity
  • Transparency ( specifically access to Trade Repository data)
  • Requirements for CCPs
  • Requirements for Trade Repositories
  • Any other Comments

Given the number of ongoing problems with EMIR compliance and the sometimes controversial nature of its implementation, this public aspect of the review will make for relatively interesting reading. Interested parties are urged to contribute.

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