Response to joint Consultation on draft RTS on risk-mitigation techniques for OTC-derivative contracts not cleared by a CCP
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More details on Insurance Europe’s position can be found in section 1 of the response.
More details on Insurance Europe’s position can be found in section 1 of the response.
Question 2. Are there particular aspects, for instance of an operational nature, that are not addressed in an appropriate manner? If yes, please provide the rationale for the concerns and potential solutions.
A descriptive approach to collateral diversification creates significant operational burden; (especially) in the case of small insurance companies, with limited exposure on derivatives, such requirements have no economic benefits.More details on Insurance Europe’s position can be found in section 1 of the response.
Question 4. In respect of the use of a counterparty IRB model, are the counterparties confident that they will be able to access sufficient information to ensure appropriate transparency and to allow them to demonstrate an adequate understanding to their supervisory authority?
Insurance Europe believes that any legislation aimed at encouraging development of internal rating based (IRB) models should take into account the nature, scale and complexity of users of credit ratings. No differentiation between IRB and external credit ratings should be made to define assets’ eligibility.More details on Insurance Europe’s position can be found in section 1 of the response.