Submission #13

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Commodity Markets Council - Europe

Respondents are invited to comment on the proposal in this section concerning the treatment of non-financial counterparties domiciled outside the EU.

CMCE supports the revised approach taken by the joint committee.

However, we also note the challenges of applying the intragroup provisions in Article 3 EMIR in the absence of Commission decisions on third country equivalence under Article 13(2) EMIR. We would encourage the Commission and ESMA to swiftly adopt such equivalence decisions in order to enable Article 3 provisions to be applied effectively.

CMCE does not have any additional comments related to the specific consultation questions. However, our comments related to Article 4 IGT of the draft RTS are included in attachment.

Respondents are invited to comment on the proposal in this section concerning the timing of calculation, call and delivery of initial and variation margins. N/A

Respondent are invited to provide comments on whether the draft RTS might produce unintended consequence concerning the design or the implementation of initial margin models. N/A

Respondents are invited to comment on whether the requirements of this section concerning the concentration limits address the concerns expressed on the previous proposal. N/A

Respondent to this consultation are invited to highlight their concerns on the requirements on trading relationship documentation. N/A

Respondents are invited to comment on the requirements of this section concerning the legal basis for the compliance. N/A

Does this approach address the concerns on the use of cash for initial margin? N/A

Respondents are invited to comment on the requirements of this section concerning treatment of FX mismatch between collateral and OTC derivatives. N/A

Upload files CMC Europe Joint Committee EMIR Risk Mitigation Consultation Response.pdf

Name of organisation Commodity Markets Council - Europe