The signatory associations welcome the opportunity to respond to the 1st ESMA Discussion Paper onEMIR.
The associations would like to underline their commitment to a safe and efficient OTC derivativesbusiness, and high regulatory standards for clearing houses. We support the direction of regulatorychange for both cleared and non‐cleared OTC derivatives, as evidenced by the progress made in theupgrade of industry infrastructure in recent years, e.g.
- 51% of the global interest rate swap market (which itself makes up over 80% of the grossnotional volume of the total OTC derivatives market) is now cleared;
- clearing and tear‐ups have reduced the gross notional value of the CDS market in excess of75% since its peak;
- trade repositories are established and operational ‐ or close to being operational – for all ofthe 5 main OTC derivatives asset classes, giving regulators increased visibility on risk in theOTC derivatives business.
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