Read our 2013 review of how non-financial counterparties (NFCs), which are a part of a group with entities that are financial counterparties (FCs), are calculating the clearing threshold and complying with European Market Infrastructure Regulation (EMIR).
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Our review 2013
Following the original review we conducted to understand how NFCs are defining their hedging activity and monitoring their status against the clearing threshold, we extended it to include NFCs that are part of a group with entities that are FCs. Between September and November 2013, we also discussed the challenges of complying with EMIR.
This information is important to NFCs that are a part of an FC group. This is because any NFC entering into positions in over-the-counter (OTC) derivatives contracts that exceed the clearing thresholds specified by ESMA under article 11 of the OTC derivative technical standards has been required to notify its competent authority under Article 10(1) of EMIR since 15 March 2013.
We generally observed the following findings from our recent discussions with NFCs that are part of a group with FCs. In some cases, these mirror the findings from our original review to understand how NFCs are defining their hedging activity and monitoring their status against the clearing threshold , but here are some additional observations.