EMIR: Pension funds position on developments in level 2

​PGGM endorses the principles of the European Market Infrastructure Regulation (EMIR), such as increased transparency, reporting obligations and market security.

Position paper

​Our first experiences of the central clearing of “Over The Counter” (OTC) derivatives and the supplementary rules on margin requirements for non-cleared OTC derivatives suggest these will carry additional risks and costs for our clients. These arrangements do not take account of the specifically low risk characteristics of pension funds.

To the position paper: EMIR: Pension funds position on developments in level 2

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