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Brief
On December 17, 2024, the European Banking Authority (EBA) published a no-action letter stating that competent authorities should not prioritize supervisory or enforcement action related to initial margin model authorisation applications due to the entry into force of EMIR 3. The letter applies until key deliverables mandated under EMIR 3 become applicable and sets a registration process for counterparties in scope, specifying information required for first applications and yearly updates.
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