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EU Regulation

EMIR

  • FIA responds to ESMA consultation on margin procyclicality

    FIA has responded to a consultation published by the European Securities and Markets Authority (ESMA) seeking input on the current calibration of the antiprocyclicality tools, and whether proposed revisions to existing Regulatory Technical Standards (RTS) may be necessary.

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  • FIA responds to EU Commission on clearing review

    FIA recommends the European Commission takes into account international practices and continues the coordination of cross-border clearing and capital frameworks at an international level.

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  • FIA and ISDA respond to the Bank of England’s approach to tiering incoming CCPs under UK EMIR 2.2

    FIA jointly with ISDA has submitted its response to the BoE’s proposed approach to tiering under UK EMIR 2.2.

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  • FIA and ISDA submit joint response to ESMA paper on clearing thresholds under EMIR

    On 19 January, FIA and ISDA jointly submitted its respond to ESMA's Discussion Paper on the review of the clearing thresholds under EMIR.

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  • FIA responds to ESMA on EMIR trade reporting

    FIA submitted a response to ESMA's consultation on September 30 on the draft Guidelines for derivatives reporting under EMIR that highlights key areas where additional clarity and guidance is required from ESMA to ensure consistent interpretation and implementation of reporting rules to enable improved data quality, accuracy and completeness of reported data under EMIR Refit.

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  • FIA and ISDA respond to ESMA's "Draft Guidelines on common procedures and methodologies on supervisory review and evaluation process of CCPs under Article 21 of EMIR"

    FIA and ISDA have responded to ESMA’s consultation on their “Draft Guidelines on common procedures and methodologies on supervisory review and evaluation process of CCPs under Article 21 of EMIR”.

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MiFID II

  • FIA EPTA response to the FCA’s CP22/12 on Improving Equity Secondary Markets

    FIA EPTA is appreciative to the FCA for taking the lead in designing an improved post-trade transparency regime which should benefit the efficiency and competitiveness of UK capital markets. FIA EPTA members found broad support for the FCA’s proposals and found them to be mostly welcome enhancements to the current approach to post-trade transparency.

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  • FIA responds to FCA Quarterly Consultation No 35

    FIA submitted a response to proposals by the U.K.'s Financial Conduct Authority regarding the UK MiFID II ancillary activities exemption calculation.

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  • FIA EPTA response to the ESMA Call for evidence On the European Commission mandate on certain aspects relating to retail investor protection

    FIA EPTA appreciates the opportunity to provide feedback to the European Securities and Markets Authority (ESMA) on the call for evidence On the European Commission mandate on certain aspects relating to retail investor protection. FIA EPTA considers that regulatory measures should be taken to encourage and highlight the benefits of exchange-listed products.

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  • FIA EPTA response to the ESMA consultation paper ESMA Consultation Paper on the Review of the MiFID II framework on best execution reports

    FIA EPTA welcomes the opportunity to respond to ESMA Consultation Paper on Review of the MiFID II framework on best execution reports. FIA EPTA would welcome the opportunity to provide further background to ESMA on the issues raised in our response. FIA EPTA agrees with the proposed change in scope of execution venues i.e. that execution venues for the purpose of the best execution reporting regime for execution venues (RTS 27) should not include ‘market makers’. 

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  • FIA contributes comments to UK HM Treasury’s Wholesale Markets Review

    FIA commented on the HM Treasury’s (HMT) Wholesale Markets review as part of the UK government’s efforts to establish how UK markets should adapt following the UK’s departure from the EU.

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  • FIA EPTA response to the FCA Consultation Paper on a new UK prudential regime for MiFID investment firms (CP21/26***)

    FIA EPTA appreciates the opportunity to provide feedback to the Financial Conduct Authority (FCA) on its third Consultation Paper regarding the implementation of the new UK prudential regime for MiFID investment firms. This document constitutes FIA EPTA’s response to the FCA’s Consultation Paper on a new UK prudential regime for MiFID investment firms (CP21/26). We welcome the FCA’s approach as set out in the Consultation Paper and agree that the FCA’s proposed rules are clear, proportionate and fit for purpose. In our response, we focus only on a limited number of areas where we believe further improvements or clarifications could be made to enable a proportionate, effective and practicable prudential regime for investment firms.

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MiFIR

  • FIA EPTA response to the ESMA MiFIR Review Consultation on the Draft RTS on Reasonable Commercial Basis

    As high-volume consumers of a variety of wholesale market data products, our members support regulatory efforts to bring more transparency to market data pricing and fairness to commercial practices. We welcome ESMA’s efforts to strengthen this framework through the proposals set out in the consultation paper and draft RTS. In order for these proposals to be effective in practice, supervisory convergence is essential particularly regarding scrutiny of data providers’ approach to implementing the fees, costs and margin provisions. Adequate supervision and enforcement of this RTS across all NCAs is also essential for it to be effective.

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  • FIA EPTA response to the ESMA MiFIR Review Consultation on RTS on the Synchronisation of Business Clocks

    FIA EPTA members are generally supportive of ESMA’s proposed changes to the RTS on synchronisation of business clocks. In relation to the proposed extension of the clock synchronisation requirements to new entities,  in general, we agree with the proposed accuracy levels for APAs, SIs, DPEs and CTPs subject to one exception: we believe that the accuracy levels for SIs with a gateway-to-gateway latency less than one millisecond should be the same as that for trading venues and their participants with the same gateway-to-gateway latency.

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  • FIA EPTA response to the ESMA MiFIR Review Consultation on assessment criteria for the CTP selection procedure

    FIA EPTA members believe a comprehensive consolidated tape is essential for improving the international competitiveness and accessibility of EU markets to international investors many of whom currently find EU markets too complex and opaque. A comprehensive low cost, real-time, pre-trade CT will support transparency, ameliorate fragmentation and will support liquidity and investor confidence, strengthening EU financial markets.

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  • FIA EPTA response consultation on the review of the central clearing framework in the EU

    FIA EPTA members believe that the Commission should firstly focus on opportunities to incentivise clearing of new transactions on EU CCPs as moving legacy positions to another CCP will create issues around higher cost and increased risk of closing and re-opening the cleared position on the market. FIA EPTA members believe that harmonisation of the different EU legal frameworks for cross-border activity would be helpful as EU CCPs require complex legal structures to ensure the enforceability of their rules in a default situation.

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  • FIA responds to ESMA consultation paper on algorithmic trading under MiFID II/MiFIR

    On 12 March, FIA responded to ESMA consultation paper MIFID II/MIFIR review report on Algorithmic Trading. FIA’s response reflects the views of FIA exchange and clearing members and trading venue members, in relation to exchange-traded derivatives.

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  • FIA responds to ESMA on market data

    FIA responded to the ESMA Consultation Paper on draft guidelines on the MiFID II/MiFIR obligations on market data from the perspective of market data users.

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