The Irish Association of Corporate Treasurers (IACT) appreciates the opportunity to comment on the ESMA “Draft Technical Standards for the Regulation on OTC Derivatives, CCPs and Trade Repositories”.
The IACT supports the overall aim of the technical standards being the reduction of risk through the use of sound and resilient practices and appropriate risk mitigation techniques. However, we are concerned that there are a number of aspects of the proposals which, if applied in the context of a non financial counterparty ...
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