Steven Maijoor, chairman of the European Securities and Markets Authority, warned that different collateralization requirements for foreign exchange derivatives in Europe and the U.S. raise regulatory-arbitrage concerns. "The real issue for FX derivatives that only a few have spotted is not the clearing obligation, but bilateral [collateralization]," Maijoor said. "The problem of international inconsistency and regulatory arbitrage is much more serious for margin for contracts that are not centrally cleared."

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