FIA EPTA position on the proposed regulation on the framework for recovery and resolution of CCPs

As end users of clearing services, FIA EPTA Members strongly support the European Commission’s objectives to ensure that both CCPs and regulators have effective tools available to mitigate the systemic risks that would emanate from a potential failure of a CCP. However, we are concerned about the detrimental impact that the inclusion of the Variation Margin Gains Haircutting (VMGH) tool will have on market participants with hedged positions in exchange-traded derivatives (ETDs).