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 market participants in times of market stress with split liquidity pools.  It also points to an incomplete impact assessment from the EC before introducing such a disruptive measure to clearing markets.