FIA EPTA appreciates the opportunity to provide feedback to the European Banking Authority (EBA) Consultation on its Guidelines on internal governance for investment firms. FIA EPTA members note that the Draft EBA Guidelines on Internal Governance are very similar to those currently in effect and applicable to CRD V and MiFID firms, with relatively few changes. As the purpose and intention of Directive (EU) 2019/2034 (“IFD”) is to put in place a prudential regulatory framework that is more appropriate for investment firms, FIA EPTA members would urge the EBA to take a similar approach in considering the appropriate governance that should be required of investment firms, which we note are generally smaller and, on balance, as non-systemic Class 2 investment firms pose no risk to the stability of the financial system.
