Comment on the regulatory standards on bilateral collateralisation of derivatives

The position paper comments on the draft regulatory standards on bilateral collateralisation of derivatives released by the European supervisory authorities EBA, EIOPA and ESMA. The standards should not oblige all counterparties to collateralise transactions between an EU-bank and a non-EU-entity. Furthermore, the standards should acknowledge bank guarantees as collateral and should ensure that the requirements for the exemption of intra-group transactions are not inappropriate strict.