Aurora Borealis
29 June 2019 Comment Letter

Consultation Document on the Draft Technical Advice on Criteria for Tiering Under Article 25(2a) of EMIR2.2

  1. Sviatoslav Rosov, PhD, CFA
  2. Josina Kamerling
CFA Institute responds to ESMA’s consultation on criteria for tiering third country central counterparties (TC-CCPs). When commenting on ESMA’s proposed indicators designed to assess the level of systemic importance of a TC-CCP for the stability of the EU or individual member states, CFA Institute draws ESMA’s attention to the work of the Systemic Risk Council (SRC), a CFA Institute sponsored institution committed to mitigating systemic risk. In particular, the comment letter refers to a letter sent by Sir Paul Tucker to the Financial Stability Board (FSB) where he stresses the urgent need for authorities to agree on a resolution regime for distressed CCPs, as recovery policies may not suffice and cannot substitute for resolution. CFA Institute welcomes ESMA’s ambitious effort to formalize the methodology used to tier TC-CCPs and thus determine their systemic importance.
View Comment Letter

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