EPTA Position Papers
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FIA EPTA response to IOSCO Consultation Report CR04/22: Exchange Traded Funds – Good Practices for Consideration
FIA EPTA appreciates the opportunity to comment on IOSCO’s proposed good practices, which we generally welcome. FIA EPTA supports open, fair, transparent and competitive markets. These principles have informed our responses. For example, we believe it is critical to ensure funds’ AP selection processes remain fair and open to new entrants, as this ultimately benefits end-investors and market resilience.
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FIA EPTA response to the UK Government Call for Evidence to support its update of the Green Finance Strategy
FIA EPTA welcomes the opportunity to respond to the United Kingdom (UK) Government Call for Evidence to support its update of the Green Finance Strategy. FIA EPTA members believe that the UK Government is at the forefront of the global fight against climate change and mitigating its impact on citizens. The UK Government showed its leadership during COP26 in Glasgow and with the review of many legislative initiatives as also this Call for Evidence shows.
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FIA EPTA response to the IOSCO Consultation Paper on Operational resilience of trading venues and market intermediaries during the COVID-19 pandemic
FIA EPTA welcomes the opportunity to respond to the IOSCO Consolation Paper on the Operational resilience of trading venues and market intermediaries during the COVID-19 pandemic. FIA EPTA members believe it an important step by IOSCO to review the resilience of financial market participants during the Covid-19 pandemic as the lessons learned will better prepare the sector for future occurrences of high volatility.
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FIA EPTA response to the ESMA Call for Evidence On Market Characteristics for ESG Rating Providers in the EU
FIA EPTA welcomes the opportunity to respond to the European Securities and Markets Authority (ESMA) Call for Evidence On Market Characteristics for ESG Rating Providers in the EU. In 2019 FIA EPTA established a Sustainable Finance Committee for its member firms to explore how liquidity providers can contribute to the green transition. FIA EPTA members believe ESG ratings are extremely relevant for EU financial markets and financial market participants.
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FIA EPTA response to the EBA CP on the Draft Regulatory Technical Standards on the specific liquidity measurement for investment firms
FIA EPTA welcomes the opportunity to respond to the EBA Consultation Paper on the Draft Regulatory Technical Standards on the specific liquidity measurement for investment firms under Article 42(6) of Directive (EU) 2019/2034. FIA EPTA would like to clarify that the concept of a liquidity mismatch between liquid assets and liquidity requirements, which is common for specific (asset management) business models like pension funds or investment funds, does not really apply to a market making model with a trading book and taking place in a CCP cleared environment or being governed by netting agreements.
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FIA EPTA response to the ESMA CfE on the DLT pilot regime
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.
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FIA EPTA response to the ESMA consultation on the review of certain aspects of the Short Selling Regulation
FIA 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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FIA EPTA Response to the Consultative Document “Prudential treatment of cryptoasset exposures by the Basel Committee
FIA EPTA welcomes the opportunity to comment on the Basel Committee Consultative Document “Prudential treatment of cryptoasset exposures”, dated June 2021. The discussions within the Basel Committee and this Consultative Document are very timely. We have reached a pivotal moment for the adoption of innovative technologies that will improve capital markets by verifiable and transparent information, higher efficiency of clearing and settlement and more liquidity. New digital assets are emerging that promise greater stability, wider acceptance and increase possible uses.
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Response by FIA EPTA to the Financial Conduct Authority Consultation Paper on enhancing climate-related disclosures by standard listed companies and seeking views on ESG topics in capital markets, (CP21/18**)
FIA EPTA welcomes the opportunity to respond to the Financial Conduct Authority (FCA) Consultation Paper on enhancing climate-related disclosures by standard listed companies and seeking views on ESG topics in capital markets. FIA EPTA members welcome the actions and responsibilities taken by the Government of the United Kingdom to work towards the common goals of reaching climate neutrality in 2050.
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FIA EPTA response to the Consultation Paper on the clearing and derivative trading obligations in view of the benchmark transition
The FIA European Principal Traders Association (FIA EPTA) appreciates the opportunity to provide feedback to the European Securities and Markets Authority (ESMA) to the Consultation Paper on the clearing and derivative trading obligations in view of the benchmark transition. We encourage ESMA to incorporate ongoing flow trading data into its analysis. Data regarding daily trading activity is important when making liquidity assessments and monitoring the market’s ongoing transition to new benchmark rates.
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