FIA EPTA welcomes the opportunity to provide feedback on the proposed deferral for ETF transactions price at NAV. Whilst it is positive to see the FCA engaging with a specific attribute of ETF trading, many of the concerns addressed by the NAV trade reporting deferral also apply to other ETF transactions priced by reference to an external reference price or benchmark.
We believe it would be similarly beneficial to investors if ETFs referencing the closing auction price or other single time instance reference values were treated consistently with ETFs executed at NAV. For example, GMOC (Guaranteed Market on Close) ETFs.
