FESE urges the European Commission to consider the overall impact that its work on the EMIR Clearing Obligation has on the final implementation of the MiFIR Trading Obligation. We would like to reiterate our rejection of the conclusions of EMSA’s Consultation Paper on the Clearing Obligation under EMIR N°1 (Section 6) as regards the exclusion of OTC equity derivatives from the clearing obligation.
We would also like to highlight that EMIR is silent on the risk that the new obligations might result in exchange trade derivatives shifting from a regulated market to an OTC environment. This would be completely at odds with the political ambitions of the G20, EMIR and MiFID II in respect of transparency in OTC derivatives.
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