emir - glossary...emir will impose an obligation on certain eu and non-eu persons to clear all otc...

Sea of Change Regulatory reforms – charting a new course

Recognition of non-EU CCPs under EMIR

November 2012 - update

Clifford Chance


Key issues 3

Why should non-EU CCPs apply for recognition under EMIR? 4

Transitional provisions 5

Conditions for recognition of non-EU CCPs under EMIR 6

What is the timetable for the Commission’s equivalence assessments? 7

What do the requirements of Title IV cover? 8

What information is required for the application? 9

Application process 10

Ongoing provisions for non-EU CCPs 11

When can recognition be withdrawn? 12

Glossary 13

Clifford Chance contacts 14

Contents

This document is intended as a summary of the matters covered. It is not intended to be comprehensive or to provide legal advice. For more information, contact one of the Clifford Chance lawyers named below

2 Recognition of non-EU CCPs under EMIR

Clifford Chance


EMIR includes extraterritorial provisions affecting non-EU CCPs that admit EU entities as clearing members EU Regulation on OTC derivatives, central counterparties (CCPs) and trade repositories (EMIR) came into force in August 2012

Non-EU CCPs may need to apply for recognition by the European Securities and Markets Authority (ESMA), including non-EU CCPs clearing cash securities and exchange traded derivatives

ESMA can only recognise a non-EU CCP if certain conditions are met In particular, the European Commission must have determined that the legal and regulatory framework for CCPs in the non-EU

state is equivalent to EU standards and provides equivalent effective access for foreign CCPs

Requires an assessment of the regulatory framework and access arrangements for all CCPs, including those clearing cash equities and exchange traded and OTC derivatives and it may not be easy for a state to comply with the criteria

Also ESMA must have entered into cooperation agreement with the non-EU states’ competent authority

No clear timetable yet for these assessments or for concluding these agreements with all affected countries

The transitional timetable that will apply to existing CCPs already active in the EU is expected to start in Q1 2013 Adoption of Regulatory Technical Standards (RTS) under EMIR triggers the start of the timetable

This may mean that there is limited time for the non-EU state to change its laws and regulations to ensure that they are equivalent to EU standards, the Commission to perform the assessment and ESMA to conclude a cooperation agreement

The RTS may come into force as early as March 2013 and existing CCPs would have to apply for recognition within 6 months

There is some uncertainty as to the extent of the ongoing EU obligations applicable to recognised non-EU CCPs and their clearing members

Key issues


Clifford Chance

Sea of Change Regulatory reforms - charting a new course

To provide clearing services to clearing members or trading venues established in the EU Article 25(1) EMIR prohibits non-EU CCPs providing clearing services to clearing members or trading venues (regulated markets or multilateral trading facilities)

established in the EU unless the CCP has been recognised by ESMA under EMIR: risk of penalties under Member State penalty regimes (yet to be adopted)

Not limited to CCPs clearing OTC derivatives, also applies to CCPs that clear exchange traded derivatives and cash securities transactions and the definition of clearing member includes firms that only clear their own business as well as firms that clear client transactions

The prohibition will prevent non-EU CCPs allowing entities “established” in the EU to participate as clearing members of the CCP (unless the CCP is recognised)

Commission has published Q&A indicating that this also prohibits non-EU CCPs allowing EU entities to participate as clearing members through a non-EU branch (however, it does not prohibit non-EU subsidiaries of EU firms participating as clearing members in a non-EU CCP or EU clients clearing business through non-EU clearing members)

This obligation may apply from 16 August 2012 (when EMIR came into force) but see below for transitional arrangements for non-EU CCPs already active in the EU

To enable counterparties subject to the clearing obligation under EMIR to satisfy that obligation by clearing their OTC derivatives in the non-EU CCP EMIR will impose an obligation on certain EU and non-EU persons to clear all OTC derivatives that have been declared subject to the clearing obligation under EMIR;

clearing must be in a CCP that is established in the EU and authorised under EMIR or a non-EU CCP that has been recognised by ESMA under EMIR

Thus, where a class of derivatives has been declared subject to the clearing obligation, a recognised non-EU CCP will be able to compete for that clearing business

In addition, where a non-EU CCP obtains recognition to clear a class of OTC derivatives not already subject to the clearing obligation, ESMA will be obliged to determine whether to extend the clearing obligation under EMIR to that class of OTC derivatives, i.e. effectively to require relevant EU and non-EU persons to clear their transactions in that class of derivatives through the non-EU CCP (pending any other CCP obtaining authorisation/recognition for that class of derivatives)

To enable EU banks and investment firms to benefit from preferential 2% risk weighting for exposures to the non-EU CCP under the EU implementation of Basel III It is possible that this preferential risk weighting may be restricted to exposures to CCPs authorised or recognised under EMIR (and may also extend to exposures of

non-EU subsidiaries included in an EU regulatory consolidation)

Impact depends on the outcome of the negotiations on the EU implementing legislation (CRD4) and whether CRD4 includes any applicable transitional provisions

Why should non-EU CCPs apply for recognition under EMIR?


Clifford Chance


EMIR includes transitional provisions for non-EU CCPs “recognised” to provide clearing services in an EU Member State in accordance with national law of that Member State If recognised before the relevant RTS are adopted by the Commission (expected to be in December 2012)

Member State competent authority must notify ESMA of that recognition within 1 month of relevant RTS coming into force (which could be as early as March 2013)

CCP must apply for recognition by ESMA within 6 months of those RTS coming into force

Until ESMA makes a decision, the national law on authorisation and recognition of CCPs continues to apply and the CCP continues to be supervised by the competent authority in the Member State of recognition

Commission FAQs interpret these transitional provisions as available to any non-EU CCP which is “active in the EU” prior to the adoption of the relevant RTS Whether or not the CCP is subject to a formal recognition process in any Member State (e.g. only a few non-EU CCPs have been formally recognised as recognised

overseas clearing houses in the UK)

These non-EU CCPs can continue to operate in the EU, notwithstanding Article 25(1) EMIR, until ESMA makes a decision on their application for recognition

But must apply for recognition within 6 months of the relevant RTS coming into force, which may be as early as March 2013, triggering the fixed timetable for the recognition process (see below)

However, ESMA cannot grant recognition unless the Commission has determined the equivalence of the non-EU state’s regulatory framework and ESMA has concluded a cooperation agreement with the relevant non-EU regulator: the risk is that the recognition timetable expires before this happens, requiring ESMA to reject the application

It may be helpful to a non-EU CCP if a Member State competent authority acknowledged the CCP’s activities with EU market participants by giving notice to ESMA under the transitional provision but the competent authority may not be aware of that activity in the absence of an existing formal recognition arrangement

Transitional provisions


Clifford Chance


CCP has applied to ESMA for recognition The CCP must provide ESMA with all information necessary for its recognition (see below)

European Commission has adopted an implementing act determining that: The legal and supervisory arrangements of the non-EU state “ensure that CCPs authorised in that ... country comply with legally binding arrangements which are

equivalent to the requirements laid down in Title IV [EMIR]” (emphasis added)

Those CCPs are subject to “effective supervision and enforcement” in the non-EU state on ongoing basis

The legal framework in the non-EU state provides for “an effective equivalent system” for the recognition of CCPs authorised under other countries’ legal regimes

CCP is authorised in the relevant non-EU state and is subject to effective supervision and enforcement ensuring full compliance with the local prudential framework

Cooperation arrangements have been established between ESMA and the relevant non-EU competent authorities specifying at least mechanisms/procedures for: Prompt exchange of information between them, including access to all information requested by ESMA on CCPs authorised in non-EU states

Prompt notification to ESMA where the non-EU authority deems a CCP supervised by it to be in breach of local requirements

Prompt notification to ESMA where a CCP supervised by it has been granted the right to provide clearing services to clearing members/clients established in the EU

Coordination of supervisory activities, including where appropriate onsite inspection

CCP is established or authorised in a non-EU state recognised as having systems for anti-money laundering and combating terrorist finance equivalent to EU standards In accordance with criteria set out in the existing common EU understanding on third country equivalence under EU anti-money laundering directive

(Source: Article 25 EMIR)

Conditions for recognition of non-EU CCPs under EMIR


Clifford Chance


EMIR envisages equivalence assessments of non-EU jurisdictions as part of the recognition process for non-EU CCPs

as part of the recognition process for non-EU trade repositories (TRs)

for the purpose of determining the exemption from the clearing, reporting and risk mitigation obligations for transactions involving a counterparty established in an equivalent non-EU jurisdiction

Commission has asked ESMA for technical advice on selected jurisdictions To assist the Commission in its assessments

To be given in two phases (see chart)

No clear timetable for the Commission to adopt its assessments after receives advice Positive assessment depends on progress in non-EU jurisdictions in adopting

and implementing regulations reflecting G20 commitments

Timing may be affected by progress on negotiations on US extraterritoriality

What is the timetable for the Commission’s equivalence assessments?


CCPs TRs Clearing, reporting

Risk mitigation

US I I I I

Japan I I I

Australia II II II

Canada II II

Dubai II

Hong Kong II II II II

India II

Singapore II

Switzerland II II II

Rest of world

Key:

Phase I ESMA to advise on equivalence by 15 March 2013

Phase II ESMA to advise on equivalence by 15 June 2013

No current request for ESMA advice on equivalence

Note: Derivatives executed on non-EU futures or options exchanges are treated as OTC derivatives under EMIR unless the exchange is considered “equivalent” to an EU regulated market under MiFID. The Commission has not published any list of equivalent exchanges under MiFID and there is no clear timetable for this assessment

Clifford Chance


Organisational requirements

• General governance and organisational requirements

• Senior management and the board

• Risk committee • Prior regulatory approval of

shareholders with qualifying holdings

• Conflicts of interest • Business continuity • Outsourcing

Conduct of business requirements

• Transparency requirements • Segregation and portability

arrangements

Prudential rules

• Exposure management • Margin requirements • Default fund • Other financial resources • Liquidity risk controls • Default waterfall • Collateral requirements • Investment policy • Default procedures • Models, stress tests and

back testing • Settlement arrangements

What do the requirements of Title IV EMIR cover?

Note: further detail can be found in the draft RTS submitted by ESMA to the Commission for endorsement


The Commission must determine whether the legal and supervisory arrangements of the non-EU state “ensure that CCPs authorised in that ... country comply with legally binding arrangements which are equivalent to the requirements laid down in Title IV [EMIR]”

Clifford Chance


The application by a non-EU CCP to ESMA must contain at least the following information: Full name of the legal entity

Identities of the shareholders or members with qualifying holdings

Note: qualifying holdings are defined to mean a direct or indirect holding in a CCP representing 10% or more of the capital or voting rights in the CCP or which makes it possible to exercise a significant influence over the management of the CCP

A list of the Member States in which it intends to provide services

Classes of financial instruments cleared

details to be included in the ESMA website in accordance with Article 88(1)(e) EMIR

Note: this article requires ESMA to include on its website details of non-EU CCPs authorised to offer services or activities in the EU, and of the services or activities which they are authorised to provide or perform, including the classes of financial instruments covered by their authorisation

Details of its financial resources, the form and methods in which they are maintained and the arrangements to secure them including default management procedures

Details on the margin methodology and for the calculation of the default fund

A list of the eligible collateral

A breakdown of values, in prospective form if needed, cleared by the applying CCP by each EU currency cleared

Results of the stress tests and back tests performed during the year preceding the date of application

Its rules and internal procedures with evidences of full compliance with the requirements applicable in that third country

Details of any outsourcing arrangements

Details on segregation arrangements and respective legal soundness and enforceability

Details on the CCP’s access requirements and terms for suspension and termination of membership

Details of any interoperability arrangement, including the information provided to the third country competent authority for the purpose of assessing the arrangement

(Source: Article 2 draft RTS submitted by ESMA to Commission for endorsement. See Annex IV of ESMA’s final report to the Commission of September 2012)

What information is required for the application?


Clifford Chance


Application

•Non-EU CCP submits application to ESMA

Completeness check

•Within 30 working days of receipt, ESMA assesses whether application is complete • If not, ESMA sets a deadline for submission of additional information •Commission equivalence assessment and ESMA co-operation agreement need not be in place at the time the application is submitted (but will need to be in place by the time ESMA makes its decision on the grant of recognition)

ESMA consults

•Competent authorities (and central banks) of Member States where CCP provides or intends to provide clearing services •Competent authorities that supervise clearing members established in the 3 Member States which make/expected to make largest contribution to CCP’s default fund over a 3 year period

•Competent authorities supervising any EU trading venues to be served by CCP •Competent authorities (and central banks) of Member States of CCPs with which interoperability arrangements have been established •Central banks for most relevant EU currencies of financial instruments cleared

ESMA decision

•Recognition process assesses whether the conditions set out above are met (independent of other equivalence assessments under EMIR) •Within 180 working days of the submission of a complete application, ESMA informs the applicant of whether its application has been granted or refused (with a fully reasoned explanation)

•ESMA must publish on its website a list of CCPs recognised by it under EMIR • If non-EU CCP is recognised to clear OTC derivatives, ESMA will then start the process for determining whether to declare those derivatives subject to the mandatory clearing obligation under EMIR (but contracts entered into after recognition are not subject to the “frontloading” requirement*)

Application process


(Source: Article 25(4) EMIR)

* Frontloading: When an EU CCP is authorised under EMIR to clear OTC derivatives, ESMA then must determine whether to declare those contracts subject to mandatory clearing. Contracts entered into after authorisation and before the mandatory clearing date may be subject to “frontloading”, i.e. may be required to be submitted for clearing after the clearing mandate takes effect.

Clifford Chance


If CCP extends range of activities or services in the EU, ESMA must review the recognition Review conducted in accordance with same procedure for initial grant of recognition

It is likely that obligations under EMIR for CCPs will generally not apply to a non-EU CCP recognised under EMIR but: EMIR imposes an obligation on CCPs to report transactions to a trade repository or ESMA

This obligation may apply to a non-EU CCP; if it did not then there would be no assurance that transactions cleared through it would be reported anywhere.

However, there may be relief from this obligation if the non-EU state is the subject of an equivalence determination by the Commission under Article 13 EMIR*

Draft RTS envisage obligations for CCPs where a client of a clearing member provides indirect clearing services in OTC derivatives, including obligations:

Not to have business practices which act as a barrier to establishment of indirect clearing arrangements on reasonable commercial terms

At the request of the clearing member to maintain separate records and accounts enabling the clearing member’s client to distinguish in accounts with the CCP the assets and positions of the client from those held for the accounts of indirect clients of the client

To identify, monitor and manage any material risks arising from indirect clearing arrangements that could affect the resilience of the CCP

These provisions of the draft RTS relate to the clearing obligation which also applies to contracts cleared by non-EU CCPs. Even so it is unclear whether these obligations would apply to or could be complied with non-EU CCPs recognised under EMIR (but an equivalence determination under Article 13 might provide relief from the relevant requirements)

Less clear whether the obligations under EMIR for clearing members will apply to clearing members of recognised non-EU CCPs, e.g. obligations to provide information about fees, to offer different levels of segregation and to comply with indirect clearing obligations

Neither ESMA nor the Commission has yet clarified the scope of the ongoing obligations of a recognised non-EU CCP or its clearing members

* Under Article 13 EMIR, the Commission may determine that the laws and regulations of a non-EU state, among other things, are equivalent to Title II EMIR and are being effectively applied in an equitable and non-distortive manner. If so, transactions where one of the counterparties is established in that non-EU state are deemed to satisfy the principal requirements of Title II (see above for the Commission’s request for ESMA advice on equivalence for these purposes). Non-EU CCPs may wish to encourage the Commission to consider an Article 13 equivalence determination at the same time as considering an equivalence determination under Article 25.

Ongoing provisions for recognised CCPs


Clifford Chance


ESMA can withdraw recognition if: Conditions for recognition are no longer met

CCP has not made use of authorisation/recognition within 12 months, expressly renounces the authorisation/recognition or performs no activity for the preceding 6 months

CCP has obtained authorisation/recognition by making false statements or other irregular means

CCP is no longer in compliance with the conditions under which authorisation/recognition was granted and has not taken the remedial action requested by the CCP’s competent authorities/ESMA within a set timeframe

CCP has seriously and systematically infringed any of the requirements laid down in EMIR

When can recognition be withdrawn?


Clifford Chance


CCP: central counterparty Commission: the European Commission Derivative: as defined in EMIR, i.e. a financial instrument as set out in points (4) to (10) Section C, Annex 1, MiFID, as implemented by the MiFID implementing

regulation EMIR: the EU regulation on OTC derivatives, central counterparties and trade repositories ESA: European Supervisory Authority (i.e. EBA, EIOPA or ESMA) ESMA: European Securities and Markets Authority EU: European Union ITS: implementing technical standards proposed by an ESA and adopted by the Commission under powers conferred by an EU regulation or directive Level 2 measure: delegated or implementing act (including ITS and RTS) adopted by the Commission under powers conferred by an EU regulation or directive Member State: member state of the EU MiFID: the EU Markets in Financial Instruments Directive OJ: Official Journal OTC derivative: over-the-counter derivative as defined in EMIR, i.e. a derivative executed outside a regulated market (as defined in MiFID) or equivalent non-EU

market RTS: regulatory technical standards proposed by an ESA and adopted by the Commission under powers conferred by an EU regulation or directive TR: trade repository

Glossary

Recognition of non-EU CCPs under EMIR 13

Clifford Chance


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Recognition of non-EU CCPs under EMIR

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emir - glossary...emir will impose an obligation on certain eu and non-eu persons to clear all otc...

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