Positions and opinions

DACSI has formulated and communicated various position papers and opinion documents.

We provided input to ESMA's Call for Evidence about the Shortening of the settlement Cycle [15 Dec 2023].

We provided input to ESMA's Call for Evidence about the SRD2 implementation. In our response, we addressed multiple issues our members observed in this phase of implementation [28 Nov 2022].

We published a further concise update of our vision on the future scenarios for securities post-trade. This Flash update can be downloaded here [7 Jul 2022].

We published an update report to our whitepaper Future scenarios for securities post-trade. This report (like the 2020 whitepaper itself) will be sent for free on request (secretariat@dacsi.nl)

The following documents can be downloaded:

our response to the ECB/Eurosystem consultative questionnaire about the need for Central Bank Digital Currency [27 Jun 2022].

our response to the consultation by The Netherlands' Ministry of Finance on the possibilities to reinforce measures against dividend stripping [26 Jan 2022].

our response to ESMA's consultation on the Review of the MiFID II framework on best execution reports [17 Dec 2021]

our response to the European Commission's consultation on the review of the CSDR [2 Feb 2021]

our response to ESMA's consultation on Guidelines on the MiFId II / MiFIR obligations on market data [11 Jan 2021]

our response to the consultation by The Netherlands' Ministry of Finance about the law proposal Wijzigingswet Financiële markten 2022. We concur with the proposed provisions for a separated "omnibus account" in the books of a bank for the money of investment firms' clients. However, we think that  restricting these provisions to accounts with a bank domiciled in The Netherlands is unnecessary and not desirable [18 Dec 2020].

our response to the consultation by The Netherlands' Ministry of Economic Affairs and Climate Policy about the law proposal Wet toetsing economie en nationale veiligheid (Economy and National Security Review Act). We strongly oppose the proposed roles for the intermediairies in the custody chain, as they are unnecessary and ineffective [7 Oct 2020].

the request by joint market associations to the European Commission for postponement of the CSDR penalty regime and for deferral of the envisaged buy-in regime; DACSI co-signed this request [22 Jan 2020]

our response to the Europan Central Bank on their consultation re the European Distribution of Debt Instruments (EDDI) initiative [9 Jul 2019]

the NL market's reaction to the Commission’s proposal for an Implementing Regulation re minimum requirements under ShRD II [9 May 2018]

DACSI's response to the NL consultation on implementation of the Shareholders Rights Directive II in NL law [27 Mar 18]

Joint NVB/DACSI response to EC consultation Fitness check on Supervisory Reporting Requirements [14 Mar 2018]

DACSI's response to ESMA's consultation on Internalised Settlement Reporting under CSDR [14 Sep 2017]

DACSI's position with regard to the next steps for the Target 2 Securities project [23 Jun 2017]

DACSI's response to ESMA's consultation on SFTR Reporting [30 Nov 2016]

DACSI's response to ESMA's consultation on participant default rules and procedures under CSDR [30 Jun 2016]

DACSI's response to the European Commission's consultation on EMIR Review [13 Aug 2015]

DACSI's response to ESMAs’ consultation on the operation of the buy-in process (under CSDR) [6 Aug 2015]

DACSI's response to the ESAs’ consultation on Risk Mitigation Techniques for OTC non-cleared derivatives (under EMIR) [10 Jul 2015]

DACSI's position paper on the Capital Market Union in response to the EC's Green Paper [13 May 2015]

DACSI's response to the ESMA consultation on MiFID II/MiFIR [2 Mar 2015]

DACSI's responses to the ESMA consultations "Technical Standards under the CSDR" and "Technical Advice under the CSDR" [18 Feb 2015]

DACSI's response to the ESMA consultation "Review of the TS on reporting under Art 9 of EMIR" [6 Feb 2015]

DACSI's position on the proposed SFT Regulation to the Europarliament Rapporteur (ECON), Mr Renato Soru [4 Feb 2015] 

DACSI's response to the ESMA Consultation paper "Guidelines on asset segregation under the AIFMD" [30 Jan 2015]

DACSI's position with regard to the proposal for Regulation on reporting and transparency of Securities Financing Transactions (SFT) [25 Jul 2014] 

Joint NVB/DACSI response to the ESMA/EBA/EIOPA consultation paper on Draft regulatory technical standards on risk-mitigation techniques [14 Jul 2014]

DACSI's input to The Netherlands' Authority for the Financial Markets (AFM) for its 2015 agenda [2 Jun 2014]

DACSI response to the European Commission's consultation document "FX Financial Instruments" [9 May 2014]

DACSI response to ESMA's consultation paper "EMIR and non-EU counterparties" [16 Sep 2013]

DACSI responseto ESMA's discussion paper "The Clearing Obligation under EMIR" [12 Sep 2013]

Joint AFME/DACSI request to LCH.Clearnet SA to migrate to Trade Date Netting [19 Aug 2013]

DACSI comments on BCBS-IOSCO's consultation on margin requirements OTC derivatives [28 Sep 2012]

DACSI response to ESMA's consultation EMIR Technical Standards of 25Jun12 [6 Aug 2012]

DACSI response to ESMA's discussion paper EMIR Technical Standards of 16Feb12 [19 Mar 2012]

DACSI remarks on ESMA's consultation short selling notification [13 Feb 2012]

DACSI response to CPSS-IOSCO's consultation on FMI Principles [29 Jul 2011]

DACSI observations to EC's DG Competition on the proposed exchanges merger [17 Jul 2011]

DACSI response to EC's consultation on CSD legislation [1 Mar 2011]

DACSI response to EC's consultation on Securities Law Directive (SLD) [21 Jan 2011]

DACSI response to EC's consultation on Derivatives and Market Infrastructures (EMIR) [9 Jul 2010]

DACSI's position on NYSE's clearing strategy for Europe [16 Jun 2010]

DACSI was surprised by NYSE Euronext’s timing of its strategic move with regard to clearing, as announced in May. With today’s knowledge of NYX plans and today’s understanding of the political and legislative landscape, DACSI thinks that users are better served by user-owned / user-governed CCPs than by a newly built couple of captive CCPs.

Response to Euroclear Nederland's White Paper "Connecting Issuers and Shareholders" [6 Oct 2009]

Joint response with NVB to EC's consultation on the OTC Derivatives Markets( Possible initiatives to enhance the resilience of OTC Derivatives Markets, SEC(2009) 914) [31 Aug 2009]

Response to the public consultation on ESCB/CESR’s draft Recommendations for Securities Settlement Systems (SSSs) and Central Counterparties (CCPs) [30 Jan 2009]