European legislator should not remove the reporting exemption for intra-group transactions

In a revised position paper, we point out obstacles to centralised risk management in the European Commission's EMIR proposal. This may be the consequence if the group reference in the definition, which derivatives qualify as hedging, is removed. Especially derivative transactions, which are executed "on behalf" of the subsidiary by the centralised unit, would no longer be considered hedges in the future. We have also supplemented our opinion with a cost estimate for the removal of the EMIR reporting exemption.