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.
Taking the example of an investment fund, we understand that there may be instances of a structural mismatch between the dealing frequency of units in these funds and the underlying assets in which the fund invests. Such a liquidity mismatch makes redemption requests harder to meet which could ultimately lead to the temporary suspension of dealings in the fund.
