CP12 has published its response to ESMA’s consultation paper on the review of RTS No 153/2013 with respect to procyclicality of margin (Link).
The response can be viewed here: Link
CCP12 highlights the following key points (which are further elaborated in the response):
- CCP12 emphasizes the performance of CCPs during the crisis and suggests that improvements should be reviewed on a more holistic basis across financial markets.
- CCP12 stresses that standardization and homogenization is needed in the bilateral markets and not for APC margin measures used by CCPs.
- Generally, CCP12 does not believe that an incorporation and enhancement of provisions of the existing Guidelines into the RTS is necessary.
- CCP12 urges ESMA to not apply an overly prescriptive approach, but rather leave it to EU CCPs what APC measures and practices are appropriate.
- CCP12 asks ESMA to coordinate its efforts with other international standard setting bodies rather than moving forward separately.
- CCP12 highlights the transparency of CCPs but also emphasize our support for future efforts on transparency, especially for the uncleared market and the practices of Clearing Members (MPPQDs).
