Many of FIA EPTA’s members are clients of direct clearing members, and therefore rely on clearing members for access to financial markets. In consequence, we are supportive of the overarching objective which the Delegated Regulation on FRANDT seeks to achieve, 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.
In this regard, FIA EPTA members specifically consider that additional regulatory requirements need to be specified so as to ensure that conflicts of interest which may exist within banking groups which offer client clearing services are effectively addressed. We welcome the opportunity to provide our comments to the present consultation. Should you need any additional clarifications or feedback, we stand ready to support the Commission with any further information it may require. We welcome the opportunity to provide our comments to the present consultation. Should you need additional clarifications or feedback, we stand ready to support the Commission with any further information it may require.