Positions

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Issue Date Contact
 
Commission’s Consultation on OTC Derivatives 12/07/2010 COM - DG MARKT
Position

Summary:

EuropeanIssuers' Response of 9 July on the Commission's Consultation on OTC Derivatives of 14 June

EuropeanIssuers has the following concerns: 

- Non-financial companies use the OTC derivative markets to manage risks. The current proposals for a clearing obligation or a requirement to post collateral do not take this sufficiently into account.
- EU non-financial companies should not be placed at a disadvantage to their competitors elsewhere. Thus a requirement for EU companies to tie up large amounts of cash which did not apply to similar companies elsewhere would be extremely unhelpful.
- Non-financial companies do not themselves constitute a systemic risk to the financial markets in the way that financial institutions may. They should not therefore be subject to the same regulatory requirements.



Position paper:

OTC_derivatives_response_20100709.pdf