Response to ESMA on indirect clearing arrangements under EMIR and MiFIR

FESE agrees with the overall objective of providing adequate protection to indirect clients, including those indirect clients that are part of longer chains.

We very much appreciate that ESMA has taken into account the concerns raised by different stakeholders and has proposed a solution. We agree with the need for clients to be offered a choice of account types but support flexibility on the selection of an omnibus account structure.