The European Association of CCP Clearing Houses (EACH) appreciates the opportunity to provide feedback to the ESMA consultation on draft Guidelines on reporting under EMIR. EACH Members welcome collaborations between ESMA and CCPs, and look forward to further engaging with ESMA and other regulators to build a robust and efficient reporting regime. Our views, in summary, are the following:
- EACH Members welcome increased guidance and kindly suggest ESMA to work collaboratively with the industry to provide more extensive guidance and worked examples of reporting.
- In particular, EACH Members believe guidance is needed for valuation reporting considering the importance of monitoring systemic risk in the financial system. ESMA expects counterparties to report the value of the contract provided by the CCPs, but in order to harmonize the CCP valuation reporting and for regulators to achieve risk oversight, we need more extensive guidance and worked examples.
- EACH Member also kindly encourage ESMA to consider the differences between ETD and OTC reporting. We believe that for ETD risk sits at the position level, and it is in regulators’ interest to focus on ETD position level reporting rather than transaction level reporting to effectively monitor systemic risk.
- It is also important for ESMA to consider proportionality. For instance, we strongly believe that reporting zero contract value on a daily basis when a positon is netted to zero adds no value to regulators, it only put additional operational burden on reporting counterparties. We believe a strong dialogue between regulators and market participant is essential to improve the reporting consistency under EMIR.
EACH response to the ESMA Consultation Paper on draft Guidelines for reporting under EMIR
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