FIA, ISDA and the European Fund and Asset Management Association have shared a paper with EU policymakers, requesting clarification on the implementation of the active account requirement under the European Market Infrastructure Regulation (EMIR 3.0) in relation to representativeness.
The associations request regulatory guidance, with a view to standardising compliance and avoiding fragmented implementation of requirements across EU member states.
In particular, the paper addresses the frequency required to determine the most relevant subcategories, the treatment of counterparties falling below the €6 billion threshold and reporting considerations for representativeness.
Read the paper here.
