EACB response ESMA discussion paper clearing obligation under EMIR

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.