FIA EPTA welcomes the opportunity to respond to the European Securities and Markets Authority (ESMA) Call for Evidence on the DLT Pilot Regime. FIA EPTA believes it is an important step by ESMA to review the DLT space as it will grow in use and importance. Over the past years, FIA ETPA Members have become increasingly active in the Digital Assets space and several members have become liquidity providers in this new and developing market.
CONTINUE READINGFIA EPTA welcomes the opportunity to respond to the EBA Consultation Paper on the Draft Regulatory Technical Standards on Pillar 2 add-ons for investment firms under Article 40(6) of Directive (EU) 2019/2034. FIA EPTA is concerned about the fact that art. 4(2) of the draft Delegated Regulation effectively creates a floor with respect to the additional Pillar 2 requirements. This is the result of the fact that the additional own funds requirements as calculated in art. 4(1) are to express both (1) as an absolute amount, as well as (2) as the ratio of that amount to own funds requirements.
CONTINUE READINGFIA EPTA welcomes the opportunity to respond to the EBA Consultation Paper on the Draft Guidelines on common procedures and methodologies for the supervisory review and evaluation process (SREP) under IFD. FIA EPTA members believe that the overarching principle of proportionality, which stems from the Level 1 legislation, should be applied across all topics covered in the Draft Guidelines and the elaboration of that principle in the regulation should be guaranteed.
CONTINUE READINGFIA EPTA welcomes the opportunity to respond to the Financial Conduct Authority (FCA) Consultation Paper on Regulatory fees and levies: policy proposals for 2022/23. FIA EPTA does not have a strong view on the proposed change as in practice we are not aware of any firms subject to IFPR that have obtained in the past such internal model approval. This is due to the fact that the conditions to implement the internal model are extremely burdensome as they were initially designed for large credit institutions. However, should the FCA allow for a relaxation of these conditions at some point in time
CONTINUE READINGFIA EPTA and FIA are concerned by current proposals under the Taxonomy and Sustainable Finance Disclosure Regulation (SFDR) that would in effect restrain the use of listed derivatives by market participants and restrict the amount of capital that can be made available for a sustainable transition.
CONTINUE READINGFIA EPTA welcomes the opportunity to respond to the Financial Conduct Authority (FCA) Discussion Paper on Sustainability Disclosure Requirements (SDR) and investment labels (DP21/4). FIA EPTA members believe that for the normalisation of sustainable investing it should be organised in a similar way as with traditional investment products. FIA EPTA members believe that the secondary markets can play a vital role in the shift towards sustainable investing.
CONTINUE READINGFIA EPTA appreciates the opportunity to provide feedback to the European Securities and Markets Authority (ESMA) on the call for evidence On the European Commission mandate on certain aspects relating to retail investor protection. FIA EPTA considers that regulatory measures should be taken to encourage and highlight the benefits of exchange-listed products.
CONTINUE READINGFIA EPTA is looking for a Senior policy advisor – Market Structure. An exciting new role – driving the European market structure discussion
CONTINUE READINGFIA EPTA welcomes the opportunity to respond to ESMA Consultation Paper on Review of the MiFID II framework on best execution reports. FIA EPTA would welcome the opportunity to provide further background to ESMA on the issues raised in our response. FIA EPTA agrees with the proposed change in scope of execution venues i.e. that execution venues for the purpose of the best execution reporting regime for execution venues (RTS 27) should not include ‘market makers’.
CONTINUE READINGFIA EPTA appreciates the opportunity to provide feedback to the European Securities and Markets Authority (ESMA) on the consultation on the review of certain aspects of the Short Selling Regulation. FIA EPTA is of the view that short-selling bans are harmful to the orderly functioning of markets. We note the unnecessary operational risks that were a consequence of short selling bans implemented inconsistently and with limited lead-time last year.
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