EMIR derivatives regulation

GDV’s position on the joint consultation paper of the European Supervision Authorities (ESA)

GDV took part in the ESAs (European Supervisory Authorities: European Insurance and Occupational Pension Authority, European Banking Authority and European Securities and Markets Authority) second consultation of draft regulatory technical standards (RTS) on OTC derivatives not cleared by a CCP.

The GDV has emphasized the following aspects:

1. To allow for a sensible application of the proposed provisions to insurers, Solvency II principles should be applicable and a respective adjustment of the initial margin model should be supported comparable to bank legislation.

2. Provisions regarding concentration limits are too prescriptive and limits proposed for government bonds need to be avoided.

3. Insurance derivatives should be exempted from the obligation to post collateral.

4. RTS should not go beyond the provisions of the regulation, i.e. intra-group exemptions should still be achievable.

The GDV’s complete comments is available in the download section.


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Comments on

draft regulatory technical standards on risk-mitigation techniques for OTC-derivative contracts