The European Association of Co-operative Banks (EACB) welcomes the opportunity to point out the co-operative banking sector's position on certain issues of particular importance related to the clearing obligation. We deem that the level 2 EU legislation should strive to combine the needs for regulation of intermediaries with those of preserving the diversity of the banking industry and cater for the peculiarities of local, co-operative and retail banks, possibly by concretely applying the principle of proportionality. Please note that we answer a selected number of questions of this ESMA consultation which are of particular concern to us. For the full paper, please download the PDF.
12 September 2013
EACB response ESMA discussion paper clearing obligation under EMIR