OTC derivatives after the introduction of EMIR
With certain aspects of the regulation on OTC derivatives, central counterparties and trade repositories (EU) 648/2012 now in force, Sam Robinson, senior associate at Nabarro, who advises on UK and EU financial services law and regulation, considers the impact of the European Markets Infrastructure Regulation (EMIR) on the industry.
With the changes that are proposed by EMIR, the proposed timeframe is clearly ambitious. This is the case even after taking into account that EMIR is being implemented on a staged basis, allowing the regulators and the industry more time to prepare for arguably the more demanding changes that will be brought in with the new regime. For example, one change that is likely to prove problematic is the requirement to provide colla-teral for trades that are not centrally cleared, which is expected to enter into force in late 2014/15…
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