The European Association of Co-operative Banks (EACB) welcomes the opportunity to contribute to the discussion around the review of EMIR. Bearing in mind the revolution that EMIR has caused to the derivatives markets and that it is one of the first regulations with a massive amount of delegated regulations drafted by ESMA (or other European supervisory authorities) we believe that a more in-depth analysis of EMIR and its implications is indeed a timely exercise.
One of the biggest problems for our smaller members is the difficulty in accessing CCPs, while other requirements have proven to be too costly and burdensome. We believe that more simple procedures could be envisaged.
For further information on this topic or to read the consultation paper, please download the PDF.