CMCE supports the revised approach taken by the joint committee.
However, we also note the challenges of applying the intragroup provisions in Article 3 EMIR in the absence of Commission decisions on third country equivalence under Article 13(2) EMIR. We would encourage the Commission and ESMA to swiftly adopt such equivalence decisions in order to enable Article 3 provisions to be applied effectively.
CMCE does not have any additional comments related to the specific consultation questions. However, our comments related to Article 4 IGT of the draft RTS are included in attachment.