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CSA Proposed National Instrument 94-101 Mandatory Central Counterparty Clearing of Derivatives Consultation


Release Date: 05/12/2015
Staff Reference: James Wood

May 12 2015


Dear Sir/Madam:

CSA Proposed National Instrument 94-101 Mandatory Central Counterparty Clearing of Derivatives

The Canadian Life and Health Insurance Association is pleased to provide comments on Canadian Securities Administrators (“CSA”) Proposed National Instrument 94-101 Mandatory Central Counterparty Clearing of Derivatives.

Established in 1894, the Canadian Life and Health Insurance Association (CLHIA) is a voluntary trade association that represents companies which together account for 99 per cent of Canada's life and health insurance business. The industry, which provides employment to over 150,000 Canadians and has investments in Canada of about $580 billion, protects almost 28 million Canadians through products such as life insurance, annuities, registered retirement savings plans, disability insurance and supplementary health plans. It pays benefits of more than $76 billion a year to Canadians and manages about two-thirds of Canada’s pension plans. Canadian life insurance companies participate as end-users in Canadian and foreign derivatives markets.

We are pleased that the CSA has decided to take the approach of creating a National Instrument regarding central counter party clearing of derivatives since this will greatly aid with ensuring harmonization across Canada. We also support the proposed phased-in approach with respect to different categories of market participants...