PensionsEurope has submitted a response to the Consultation Paper on Draft regulatory technical standards on risk-mitigation techniques for OTC-derivative contracts not cleared by a CCP under EMIR. In its response to this consultation of the European Supervisory Authority, PensionsEurope has expressed its concerns on the impact that the proposed measures would have on IORPs when trading derivatives. It is PensionsEurope’s view that said measures go against the rationale behind the temporary exemption from the clearing obligation granted to IORPs and their asset managers under EMIR. It also fails to recognise the very low counterparty risk of IORPs as well as the way they use derivatives to mitigate financial risk.
The PensionsEurope response is available here.