ECB Response To Commission Review Of EMIR Implementation

On September 4, 2015, the European Central Bank (ECB) published an executive summary of its response to the consultation carried out by the European Commission to assist the Commission in its review of EMIR implementation.

The ECB's main recommendations include:

1. further study of the use of OTC derivatives by non-financial counterparties, with a view to assessing whether the current framework causes undue restrictions on such parties accessing the OTC derivatives market to support their regular business;
2. further enhancing margin requirements in order to mitigate procyclicality;
3. additional requirements to guarantee the resilience of portfolio margining models in times of stress;