EFAMA supports every efforts made to enhance financial markets regulation which reinforces the stability and the transparency of the financial system.

In that perspective, EFAMA welcomes the opportunity to comment on the ESMA consultation paper on the Draft RTS and ITS under SFTR and amendments to related EMIR RTS.

Prior to replying to the consultation, we wish to make the following general remarks

EFAMA, welcomes the opportunity to comment on the ESMA Discussion Paper (“DP”) on the trading obligation for derivatives under MiFIR.

As a principle, EFAMA supports every effort made to enhance financial market regulation which reinforces the stability of the financial system, of which MiFIR is an important part.

Prior to replying to the consultation, we wish to make the following general remarks.

As a principle, EFAMA supports every effort made to enhance financial market regulation which reinforces the stability of the financial system, of which EMIR is an important part.

Prior to replying to the consultation, we wish to make the following general remarks.

Firstly, we fully support the points raised by ESMA that recognizes that several types of counterparties active in the OTC derivatives markets are facing numerous issues in relation to the access to central clearing due to:

EFAMA is grateful for the opportunity to contribute to the drafting of the Regulation through a consultation and we appreciate the effort of the regulator to adopt an approach to reporting consistent with EMIR and to develop, where more efficient, a different reporting logic.