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. This document constitutes FIA EPTA’s consolidated response to the EBA’s IFR/IFD Level 2 consultations. In our response we focus on a number of key areas where we believe the EBA should consider amending the draft RTS/ITS to enable a proportionate, effective and practicable prudential regime for investment firms, in line with the original intent of the Investment Firm Review. FIA EPTA members appreciate the EBA’s consideration of our comments and suggested solutions and stand ready to provide any further input as required.
