ALFI responds to the ESMA discussion paper on the review of the clearing thresholds under EMIR.

In order to alleviate counterparties to fall unexpectedly under the clearing obligation, ALFI recommends a temporary grandfathering to exclude the ETDs traded in the UK from the calculation of the exposure to be compared to the clearing threshold. This grandfathering would last until similar ETDs are proposed by markets located in the EEA.

Moreover and in line with its previous advocacy on the topic, ALFI supports an exclusion of the physically foreign exchange forwards and swaps transactions from the calculation of the exposure against the clearing threshold, similarly to the regime benefiting to the NFCs.

View the ALFI response.