ISDA, the British Bankers' Association (BBA), the Association of Financial Markets in Europe (AFME) and the Italian brokers association have submitted a detailed response to ESMA’s consultation paper and draft TS on EMIR. Many of the comments focus on the international impact of key measures, asking for clarification on how they will have effect in an international context. A further set of detailed comments surrounds how EMIR will cover non-financial counterparties. (Source: Industry Responds on EMIR Technical Standards)