The European Association of Central Counterparties Clearing Houses has welcomed the opportunity to respond to the EBA Consultation Paper on Regulatory Technical Standards on the Capital Requirements for CCPS under the draft Regulation on OTC Derivatives, CCP’s and Trade Repositories.

While EACH strongly supports the objective of bringing more business in standardised OTC derivatives within the ambit of CCP clearing as a means of managing systemic and contagion risk, EACH has highlighted seven main concerns including: clarification to equally treat spot products and derivatives, notification threshold should be deleted and the contribution to other CCP ’s default fund should be treated in harmony with the CRR.