On 17 August 2015, Insurance Europe published a response to the European Commission consultation on review of the European Market Infrastructure Regulation (EMIR).  Notably, in its response, Insurance Europe suggested possible solutions to the insufficient possibilities for long-term investors (such as insurers) to transfer non-cash collateral with central counterparties (CCPs).  These include (a) a permanent exemption from the central clearing obligation for insurance companies that use derivatives for hedging and (b) encouragement for CCPs to develop tailored solutions for insurance companies (allowing for non-cash collateral as variation margin).  Insurance Europe also noted that it should be clarified that the EMIR does not apply to insurance products.