EFAMA welcomes the opportunity to respond to the EC’s targeted consultation on the EU’s central clearing framework. We are pleased to find in this consultation document a fair reflection of the complexity of the CCP ecosystem and consistency with the issues raised in previous dialogues held with the European Commission. In that same spirit, we hope in our response to provide feedback that resonates with the EC’s broader policy objectives while minimizing systemic risk and undue harm to our industry.

The European Commission’s proposal on MiFIR establishes the blueprint for a consolidated tape (CT) for Europe’s capital markets. It also significantly alters the competitive market structure brought about by MiFID II by introducing greater transparency requirements. Finally, it addresses important issues around market data costs.