EFAMA offers a detailed view on the active accounts proposal in this paper.  Costs to the end investor are broken down into two main buckets i) operational build-out and ii) in nominal terms the much larger impact of loss of netting efficiencies.  Potential impacts on financial stability are also examined, with a focus on the widening basis which will result from large volumes of one-directional flows onto an EU-CCP.  The impact on margins and procyclicality are also studied.  The analysis points to increased liquidity risk for

EFAMA appreciates the opportunity to comment on the EMIR 3.0 proposal reforming the clearing framework in the EU. We share the objectives of this review which seek to ensure financial stability in the EU, and the well-functioning of the existing central clearing framework. We understand the objective to reduce excessive exposure to substantially systemic CCPs over time, though we maintain that any regulatory measures should be proportionate to the regulatory rationale, and should not unduly harm market participants.