The International Swaps and Derivatives Association, Inc.1 (“ISDA”) is pleased to have the opportunity to comment on the European Market Infrastructure Regulation (“EMIR”), the proposed EU Commission regulation on OTC derivatives, central counterparties and trade repositories.  ISDA is writing this letter to explain and emphasise the importance of EMIR having sufficient flexibility so as to accommodate indirect clearing and provide scope for guidance and practice from the European Securities and Market Authority (“ESMA”) in due course.