ESMA is consulting on draft RTS relating to indirect clearing for OTC derivatives under EMIR and exchange-traded derivatives under MiFIR. As reported in Legal Shorts previously, ESMA noted during its consultation on draft MiFIR RTS on indirect clearing for ETDs that a number of important concerns had been raised relating to the EMIR RTS and that alternative requirements for both OTC derivatives and ETDs would therefore need to be developed.  Issues addressed by the consultation include: (i) accounts structure and segregation models; (ii) default management requirements; and (iii) longer chains involving more than one indirect client. Comments are invited by 17 December 2015.