Derivative Rules (EMIR) (Regulation)

However, cep criticises the fact that the requirement for clearing members and their clients to comply with “fair, reasonable and non-discriminatory” terms represents an unnecessary intervention in the freedom of contract. Pension funds should also, in principle, be subject to the clearing obligation for OTC derivatives. cep, however, regards as justifiable the EU Commission’s proposal for a final transition phase for the clearing obligation for pension funds. The planned double reporting requirement for the party subject to the reporting obligation is however unnecessarily bureaucratic.