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In its response to the ESMA consultation on conflicts of interest management, ECC raised the importance of exchanging best practices between central counterparties (CCPs), as well as ensuring there is a consistent implementation across CCPs. It is, however, important to take into account the particular business situations of CCPs to ensure that measures are not disproportionate. In this views, especially possible restrictions to the management or the supervisory board have to be seen critical, according to ECC.
The full position paper is available under the following link:
