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NSA response to ESMA Consultation Paper on the trading obligation for derivatives under MiFIR

Posted on August 09, 2017

The NSA notes and appreciates that ESMA has listed to the feedback provided from several stakeholders regarding some of the questions raised in the Discussion Paper (DP).

 In particular, the NSA would like to express support to the decision by ESMA not to include the IRS 10 yr SEK in the TO. As mentioned in our reply to the DP these contracts are not liquid and 99 % OTC-traded. We fully agree to ESMA’s solution that contracts denominated in a particular currency should only be considered to be subject to the CP where at least 3 tenor points are considered to be liquid.

 The NSA also appreciate that ESMA has put an effort to improve the data and methodology from the discussion paper to this consultation. For example, we agree to the change to effective date instead of the execution date.

 However, we would like to raise some key points elaborated in our response document.