The ACT, under the auspices of the EACT, together with other corporate end-user associations, has issued a position paper outlining the priorities from the end user perspective for the EMIR REFIT review.
Key areas include:
- maintaining the commercial hedging exemption,
- amending the proposed reporting structure, and
- extending the proposed asset class by asset class assessment of the clearing obligation to bilateral margin requirements.
The European Commission proposal issued in May is available here, and their factsheet here.