EACT Response to the Consultation on Margin Requirements

The EACT has responded to a joint consultation held by the European Supervisory Authorities on the risk-mitigation techniques for OTC-derivative contracts not cleared by a CCP. The margin requirements are meant to apply only to non-financial counterparties above the clearing threshold; however in our response we highlight that non-financial counterparties below the clearing threshold must be exempted from the requirements by default and that any prior agreement on exemption should not be necessary.