EPTA Position Papers
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FIA EPTA response to the ESMA Consultation Paper on Guidelines on the MiFID II/MiFIR obligations on market data
FIA EPTA members welcome the opportunity to respond to this Consultation Paper on Guidelines on the MiFID II/ MiFIR obligations on market data. FIA EPTA has consistently supported ESMA’s work on market data issues and we very much welcomed ESMA’s review report from December 2019 and its draft Guidelines which build on this report. As we have shown in our response to ESMA’s previous consultation in 2019, user data fees are high and have increased over the past years.
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FIA EPTA response to the FCA Call for Input on accessing and using wholesale data
FIA EPTA welcomes the opportunity to respond to the FCA Call for Input on accessing and using wholesale data. Below, we respond to the FCA’s questions in relation to trading data, benchmarks and market data vendor services. FIA EPTA members observe that user data fees are high and have increased over the past years. Empirical data which we have analysed substantiates this. We also observe that new fees have been added and that market data policies and agreements are increasingly complex.
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FIA EPTA response to the FCA’s consultation paper on its approach to international firms
The FIA European Principal Traders Association (FIA EPTA) appreciates the opportunity to respond to the FCA’s consultation paper on its approach to international firms and the process for setting out the FCA’s expectations of such firms operating in the United Kingdom under its framework. FIA EPTA is supportive of the FCA’s proposed flexible approach to the regulation of international firms.
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Response by the FIA EPTA to the ESMA consultation on MiFID II/ MiFIR review on the functioning of Organised Trading Facilities (OTF)
FIA EPTA supports transparent, robust, and safe markets with a level playing field and appropriate regulation for market participants. We consistently support the aim of the market structure reforms laid out in MiFID II/MiFIR and welcome the opportunity to respond to this consultation on MiFID II/ MiFIR review on the functioning of Organised Trading Facilities (OTF). Our members are aware of various systems and market practices which seem to conflict with MiFID II expectations for multilateral systems.
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Response by FIA EPTA to the ESMA consultation on MiFIR review report on the obligations to report transactions and reference data
FIA EPTA supports transparent, robust and safe markets with a level playing field and appropriate regulation for market participants. We consistently support the aim of the market structure reforms laid out in MiFID II/MiFIR and welcome the opportunity to respond to this consultation on the obligations to report transactions and reference data.
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Higher cost, higher risk: The impact of the closed market structure on the European warrants market: price analysis and recommendations
In June 2020, FIA EPTA conducted research on the impact of the single liquidity provider structure on the European warrants market and compared it with the listed options market. We examined the pricing of comparable warrants and options products with matching risk/reward profiles and the impact of differing market conditions on investors’ ability to trade in both markets. The conclusions of this research are clear: investors trading on Europe’s warrants markets are losing millions of euros a year because of its ‘closedshop’ structure which inflates prices compared to comparable products on more open and competitive markets.
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FIA EPTA response to the ESMA Call for Evidence on RTS 1 and 2
FIA EPTA response to the ESMA Call for Evidence on RTS 1 and 2. The purpose of this exercise by ESMA is to gather input and views on practical issues related to the application of RTS 1 and RTS 2 that market participants have identified since the application of MiFID II/ MiFIR. The response builds on comments made by FIA EPTA earlier to ESMA and the European Commission for their Equities, Non-equities and general MiFID II consultations. Additional comments by FIA EPTA relate to issues that so far have not been picked up or actioned by ESMA.
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Response by the FIA EPTA to the FCA Discussion Paper on a new UK prudential regime for MiFID investment firms
FIA EPTA appreciates the opportunity to provide feedback to the Financial Conduct Authority (FCA) on its Discussion Paper regarding the implementation of the new UK prudential regime for MiFID investment firms. Market making and liquidity provision (also referred to as principal trading or dealing on own account) is a distinct activity that is undertaken by non-systemic investment firms rather than banks, in a highly dispersed and varied ecosystem of independent Principal Trading Firms.
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FIA EPTA response to the European Commission consultation on the re-bundling of research and execution costs under the MiFID II quickfix
FIA EPTA welcomes the opportunity to provide feedback on the proposed MiFID II Quick-fix rules in relation to research on companies seeking alternative financing. Overall, FIA EPTA members believe that the unbundling rules laid out in MiFID II removed an important source for conflicts of interest and has reinforced the independence of research. We note that the market has fully implemented and adapted to research unbundling with clients now accustomed to receiving disaggregated cost information that differentiates between costs attributable to research from those related to execution.
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Consolidated response by FIA EPTA to the EBA consultations on IFR/IFD Level 2
FIA European Principal Traders Association (FIA EPTA) appreciates the opportunity to provide feedback to the European Banking Authority (EBA) on the implementation of the new regulatory framework for investments firms (IFR/IFD). FIA EPTA has consistently welcomed the new prudential regime for investment firms contained in the Investment Firm Regulation and Directive (IFR/IFD), which is aimed at creating a tailored and proportionate prudential framework for firms such as those we represent.
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