ALFI responds to ESMA consultation paper on alignment of MiFIR with changes introduced by EMIR Refit

29 Nov 2019 | Statements and Position Papers  


On 22 November 2019 ALFI responded to ESMA’s consultation seeking stakeholders views on the necessity and appropriateness of aligning the Derivatives Trading Obligation (DTO) under MiFIR with changes made under EMIR Refit to the Clearing Obligation (CO).

ALFI confirmed its recommendation to exempt of DTO the Small Financial Counterparties in the meaning of EMIR. Moreover, the MiFIR should not add an unnecessary trading obligation to contracts already cleared through a CCP. Read ALFI's response.