The European Securities and Markets Authority is seeking comments on its proposal to permit European-based clearing houses (CCPs) to set margin requirements anticipating a one-day liquidation period, provided clearing members post client funds on a gross basis. Currently, EU CCPs must set margin requirements anticipating a two-day liquidation period; however clearing members are required to post client funds on a net basis only. ESMA recommends that CCPs would, going forward, be permitted to utilize either of the two approaches. If the EU were to adopt ESMA’s recommendation, it would be easier for the EU to recognize US CCPs as subject to equivalent regulatory oversight as EU CCPs. A determination of equivalency is necessary for US CCPs to offer clearing services in Europe. ESMA will consider comments submitted through February 1, 2016.