Response to consultation on Guidelines on the treatment of CVA risk under SREP

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Question 6: Do you agree with the scope of derivative transactions to be included into the calculation of hypothetical own funds requirements for CVA risk?

We feel that any removal of the exemption of transactions with pension scheme arrangements from the CVA calculation would undermine the temporary exemption provided to pension funds under EMIR and would make the non-cleared OTC derivatives markets unworkable for pension funds by disproportionately increasing the cost of these derivatives. We are concerned that European regulators tasked with implementing the regulation are considering overriding key terms agreed as part of European level 1 policy-making.

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