EACT News
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Comments in response to ESMA consultation paper: Draft Technical Standards for the Regulation on OTC Derivatives, CCPs and Trade Repositories
6/8/2012
The EACT welcomes the work done by ESMA to develop the draft technical standards covered by this consultation paper. In the aim of providing the most constructive support to ESMA we are limiting our comments to the areas of most concern in the drafting. In all cases the views we express are done so from the position of non-financial counterparties, in other words the real economy end-users of the financial system.
Please click here to read the EACT's comments
EACT Response to EC Green Paper ("Towards an Integrated European Market for Card, Internet and Mobile Payments")
12/4/2012
The EACT has offered a response to the recent EC Green Paper "Towards an Integrated European Market for Card, Internet and Mobile Payments". We applaud the EC's policy to inform stakeholders and increasingly engage them in the creation of new legislation and the governance of basic network services and infrastructures like payments. We also believe the Green Paper consultation to be an important step forward to enlarge and reinforce SEPA Governance.
Please click here to read the EACT's response.
EACT Response to ESMA/EBA/EIOPA discussion paper on risk mitigation techniques for OTC derivatives
3/4/2012
The EACT has responded to the discussion paper from ESMA/EBA/EIOPA on risk mitigation techniques for OTC derivatives. The crucial areas covered by the document concern the potential requirements for collateral on OTC derivative transactions by corporates where the corporate concerned is above the 'clearing threshold' and the contracts cannot be cleared through a CCP. We are making two particularly important points: that there appears to be a fundamental inconsistency in the regulatory suggestion that banks should not be allowed to take a limited credit position on their OTC derivative activity with corporates, whilst banks are at the same time free to take credit risk through their lending activities; and that we are strongly opposed to a one-way exchange of collateral between the banks and corporates. Our response is HERE and you can view the ESMA/EBA/EIOPA discussion paper HERE.
EACT response to ESMA consultation on the implementation of the new derivatives regulation
19/3/2012
The EACT has made a submission to the European Securities and Markets Authority (ESMA) on some fundamental issues in the Level 2 implementation of the new regulation of derivatives (EMIR). The EACT's document addresses areas of crucial importance to corporate treasurers, including the definition of derivative positions that will meet the test for exemption from central clearing and the working of the clearing threshold. You can find our submission by clicking here and the ESMA paper by clicking here.
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