January 2013

LSEG response to ESMA’s consultation paper on ‘Guidelines for establishing consistent, efficient and effective assessments of interoperability arrangements’

The London Stock Exchange Group has provided a response to ESMA’s consultation paper on ‘Guidelines for establishing consistent, efficient and effective assessments of interoperability arrangements’. In our response we make the following points:

• While we agree that a CCP should assess and understand the risk management models of the other interoperating CCPs, there is a risk that the guidelines seek to require a CCP, in effect, to duplicate the assessment that the regulators/supervisors have already made in authorising a CCP under EMIR;
• We agree that the harmonisation of risk management models could be a useful process in terms of improving and challenging CCPs’ respective risk models. However, to reflect the provisions of EMIR, it should be clear that there is no requirement to pursue or implement harmonisation;
• Any rule changes of a CCP that directly impact an interoperability arrangement should be agreed with the other interoperating CCPs. However, all other rule changes, should not require notification to the interoperating CCPs earlier than other participants/clearing members.

LSEG Response to ESMA's consultation paper on 'Guidelines for establishin consistent, efficient and effective assessments of interoperability arrangements'(file pdf - 64 KB)