FIA EPTA members are supportive of the overarching objective of the FRANDT concept which is to increase access to client clearing services by ensuring that clearing members provide clearing services on fair, reasonable, non-discriminatory, and transparent terms. However, these requirements should be carefully calibrated in order to ensure that FRANDT will not inadvertently decrease access to clearing or raise the costs for providing clearing services. Additionally, FIA EPTA members strongly encourage ESMA to also consider specifically addressing conflicts of interest as part of its technical advice.
