As a principle, EFAMA supports every effort made to enhance financial market regulation which reinforces the stability of the financial system, of which EMIR is an important part.
Prior to replying to the consultation, we wish to make the following general remarks.
Firstly, we fully support the points raised by ESMA that recognizes that several types of counterparties active in the OTC derivatives markets are facing numerous issues in relation to the access to central clearing due to: