Insurance Europe has responded to a European Commission consultation on the review of the European Market Infrastructure Regulation (EMIR).

In its response, Insurance Europe indicated that there are not sufficient possibilities for long-term investors, such as insurers and pension scheme arrangements, to transfer non-cash collateral with central counterparties (CCPs). Therefore, Insurance Europe believes that there are two possible solutions to address the concern of cash:

• The Commission should consider a permanent exemption from the central clearing obligation for both pension funds and insurance companies that use derivatives for hedging.
• The Commission should also encourage CCPs to develop tailored solutions for both pension funds and insurance companies, allowing for non-cash collateral as variation margin.

Insurance Europe also said that the obligation for dual-sided reporting (DSR) should be removed and replaced by a requirement for one-sided reporting.