ALFI responds to ESMA consultation on commercial terms for providing clearing services under EMIR (FRANDT)
3 December 2019 | Statements and Position Papers
On 2 December 2019, ALFI responded to the consultation seeking stakeholders views on ESMA’s draft technical advice to the Commission on how to specify the conditions under which the commercial terms are to be considered to be fair, reasonable, non-discriminatory and transparent (FRANDT) when providing CCP clearing services to clients in accordance with Article 4(3a) of EMIR.
ALFI generally agrees with the criteria proposed by ESMA, but also suggested a number of dimensions to take into account where the end-client is a small (fund) financial counterparty. Read the response.