The European Fund and Asset Management Association (EFAMA) welcomes the opportunity to respond to this important review of RTS 153/2013 and accompanying guidelines, in light of the procyclicality witnessed during the peak volatility of the Covid crisis. European CCPs already have standard anti-procyclicality tools in their rulebooks and this did lead to less volatile moves in margin in Europe versus other jurisdictions.
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.