The European Association of CCP Clearing Houses (EACH) welcomes the opportunity to provide feedback to the ESMA consultation on clearing and derivative trading obligations in view of the benchmark transition. In summary, EACH Members:
- Overall support the proposals included in the ESMA consultation;
- Would appreciate if international coordination was ensured to the extent possible by, for instance, aligning with the implementation timing proposed by the Bank of England in its consultation “Derivatives clearing obligation – modifications to reflect interest rate benchmark reform: Amendments to BTS 2015/2205”;
- Notice that SOFR is a good active liquid market and has received additional stimulus by e.g. the SOFR First initiative. Nonetheless, EACH Members believe that authorities should coordinate and implement a consistent approach across jurisdictions to the extent possible.
- Encourage ESMA to further assess whether TONAR OIS (e.g., those with shorter maturities) would meet the requirements for being subject to the clearing obligation under EMIR, either at the time of the ESMA’s final report or once the transition is more advanced.
For more information, please visit our website www.eachccp.eu
