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Position Papers
Victoria Cummings

Joint association call to safeguard the diversity of participation in the EU ETS

Imposing restrictions on who may or may not participate in the EU ETS would significantly weaken the market, putting at risk the EU’s ability to meet its climate goals in a cost-efficient manner.

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10 May 2022
Position Papers
Victoria Cummings

Joint association paper on margining liquidity support and eligibility of guarantees and non-cash collateral

This response has been compiled by EACH, EFET, Eurelectric, Eurogas and Europex and reflects the views of their respective memberships

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9 May 2022
Consultation Responses
Victoria Cummings

Europex response to ESMA’s Opinion on the trading venue perimeter

We do not agree with the view that a system where on one side of any trade (buy side or sell side) there is always the same party should be considered multilateral simply because the system is operated by a third party (draft ESMA opinion no. 24).

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29 April 2022
Consultation Responses
Victoria Cummings

IOSCO Consultation: Principles for the Regulation and Supervision of Commodity Derivatives Markets

Europex is fully aligned with the core objectives of the Principles to ensure that commodity derivatives markets can serve their fundamental role of facilitating fair and efficient price discovery and hedging in a transparent, secure and well-regulated trading environment, while remaining free from market manipulation and other abusive practices.

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12 January 2022
Consultation Responses
Victoria Cummings

ACER public consultation on harmonised allocation rules for long term transmission rights in accordance with the FCA Regulation

We support ACER’s approach to delete Article 59(5) of the proposal, which proposes a cap on remuneration of LTTRs in case of fallback allocation. We do not see adequate justification to extend the HAR Article 59 compensation caps to LTTR remuneration during decoupling events.

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27 August 2021
Consultation Responses
Victoria Cummings

ESMA Consultation on Technical Standards for Commodity Derivatives – MiFID II Recovery Package

We welcome the opportunity to provide feedback to ESMA’s draft proposals for the review of RTS 21 and ITS 4 as well as the proposal for new technical standards for position management controls. Europex’ members have gained extensive experience with the implementation of the MiFID II position limit regime and position management provisions.

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15 July 2021
Consultation Responses
Victoria Cummings

Draft Delegated Act on MiFID II Ancillary Activity Exemption

Europex welcomes the opportunity to provide feedback to the Commission’s public consultation on the draft delegated act for amending the ancillary activity exemption (AAE) in

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24 June 2021
Consultation Responses
Victoria Cummings

Auctioning of statistical transfers: a more efficient tool for Member State cooperation on renewable energy targets for RED III

Europex welcomes the opportunity to provide feedback to this draft delegated regulation. While the current proposal for the Union Renewable Development Platform (URDP) is designed

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27 May 2021
Consultation Responses
Victoria Cummings

Targeted consultation on the review of the Directive on financial collateral arrangements

We see benefit in adding the emission allowances to the definition of financial instruments in the FCD, making it also more closely aligned to the financial instruments definition in Annex 2 of Directive 2014/65/EU (MiFID II).

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10 May 2021
Consultation Responses
Victoria Cummings

VAT rules for financial and insurance services

Europex welcomes the opportunity to contribute to the present consultation. In our response, we highlight that the regime on VAT rules for financial services subject

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3 May 2021
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