CCT Joint Comment Letter: The Corporate End-User Community and EMIR

RE: The Corporate End-User Community and EMIR

The signatories to this letter are companies and organisations that represent companies that use derivatives to hedge real economic business risks and that contribute significantly to Europe’s economy, including by employing millions of people throughout the EU.

We have joined together in this letter to urge the Commission, in connection with its ongoing review of the European Market Infrastructure Regulation (“EMIR”) and the Capital Markets Union Cumulative Impact Assessment, to propose adjustments to EMIR’s reporting requirements for non-financial counterparties (“NFCs”) below the clearing thresholds (“NFCminuses”).

We have serious concerns that corporates using derivatives for hedging purposes today are unnecessarily and disproportionately burdened by such requirements. The use of derivatives to hedge commercial risk has key economic benefits. It allows businesses—from manufacturing to healthcare to agriculture to energy to technology—to improve their planning and forecasting, manage unforeseen and uncontrollable events, offer more stable prices to consumers and contribute to economic growth. Imposing unnecessary burdens on these hedgers restricts job growth, decreases investment and undermines our competitiveness in Europe—leading to material cumulative impacts on corporate end-users and our economy.

Download the full comment letter (PDF)