ESA joint discussion paper risk mitigation measures NAPF response - March 2012
The response focuses on the suggestion in the European Supervisory Authorities’ Discussion Paper that bilateral OTC derivatives be made subject to Initial Margin requirements. The proposal goes way beyond what is included in the text of the Derivatives Regulation (EMIR) agreed by the Council of Ministers and would undermine the intention of the temporary exemption from the clearing obligation that the Regulation provides for pension schemes.
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