EFAMA appreciates the opportunity to comment on the EMIR 3.0 proposal reforming the clearing framework in the EU. We share the objectives of this review which seek to ensure financial stability in the EU, and the well-functioning of the existing central clearing framework. We understand the objective to reduce excessive exposure to substantially systemic CCPs over time, though we maintain that any regulatory measures should be proportionate to the regulatory rationale, and should not unduly harm market participants.
Unlocking private investment to fund Europe's triple transitions
EFAMA’s publication lays out the asset management sector’s policy priorities for the next five years, building on the in-depth expertise of our members. This includes practical recommendations for keeping Europe competitive and developing deeper, more integrated and liquid capital markets in Europe.