Market Structure
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FIA EPTA response to the HM Treasury Consultation Paper on the Wholesale Markets Review
The FIA European Principal Traders Association (FIA EPTA) appreciates the opportunity to provide feedback to the HM Treasury Consultation Paper regarding the Wholesale Markets Review. FIA EPTA agrees that the breadth of the current definition of a ‘multilateral system’ has created ambiguity about the regulatory perimeter which should be clarified. This has been particularly acute for brokers arranging transactions over the phone (so called “voice brokers”) and technology firms innovating new ways of bringing together buying and selling interests.
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FIA EPTA response to the Consultation Paper on the clearing and derivative trading obligations in view of the benchmark transition
The FIA European Principal Traders Association (FIA EPTA) appreciates the opportunity to provide feedback to the European Securities and Markets Authority (ESMA) to the Consultation Paper on the clearing and derivative trading obligations in view of the benchmark transition. We encourage ESMA to incorporate ongoing flow trading data into its analysis. Data regarding daily trading activity is important when making liquidity assessments and monitoring the market’s ongoing transition to new benchmark rates.
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European Commission consultation on permanently lowering the relevant threshold for the notification of significant net short positions in shares
FIA EPTA welcomes the opportunity to respond to the European Commission’s consultation on permanently lowering the relevant threshold for the notification of significant net short positions in shares. Short selling plays an important role in ensuring the proper functioning of financial markets in terms of liquidity and efficiency of price formation. It enables investors to manage risk and marketmakers to facilitate risk transfer for others by hedging their positions through buying and selling shares.
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FIA EPTA response to the European Commission public consultation on a retail investment strategy for Europe
The FIA European Principal Traders Association (FIA EPTA) appreciates the opportunity to provide feedback to the European Commission Public consultation on a retail investment strategy for Europe. The FIA European Principal Traders Association (FIA EPTA) appreciates the opportunity to provide feedback to the European Commission Public consultation on a retail investment strategy for Europe. FIA EPTA members believe that the current retail investor protection framework is an important tool to ensure retail participation in capital markets. However, an update is necessary. Over the past years, retail participation on lit markets has gone down, and the ways in which retail investors participate in the markets has changed. New technologies and platforms have emerged and are rapidly changing how retail investors interact with the market.
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FIA EPTA response to FCA CP21/09 on Changes to UK MIFID’s conduct and organisational requirements
FIA EPTA welcomes the opportunity to respond to the FCA’s consultation on changes to UK MIFID’s conduct and organisational requirements with a particular view on best execution reports. We agree with the FCA assessments that, in their current form, RTS 27 (quarterly reports) and RTS 28 (annual reports) have not achieved their policy goal of enhancing investor protection or improving information on execution quality and order routing.
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FIA EPTA, ISDA and FIA joint response to the European Commission's targeted consultation on the functioning of the European Supervisory Authorities
The Associations consider that supervisory convergence and the removal of cross-border impediments should be the primary focus of the ESAs. Should further direct powers be considered for ESMA, the Associations support a targeted approach and suggest several areas where ESMA has a strong and direct role to play. The Associations have been fully supportive of the creation of the ESAs, which have played a crucial role in developing EU financial markets and we applaud the ESAs for all their achievements over the past 10 years. The ESAs will continue to be vital in the furtherance of an effective Capital Markets Union (CMU), and we will be working closely with the European Commission and the ESAs on an ongoing basis to continue to evolve safe and efficient EU capital markets.
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FIA EPTA Letter to Central Bank of Ireland CP on Enhancing Engagement with Stakeholders
FIA EPTA welcomes the opportunity to respond to the Central Bank of Ireland Consultation Paper on Enhancing our Engagement with Stakeholders. On behalf of FIA EPTA’s Irish and other members, we would like to express our continued appreciation of the CBI's open and constructive dialogue with our industry. FIA EPTA members believe that proposals 2 and 3 in the Consultation Paper are important initiatives that will strengthen the relationship between the CBI and wider financial markets stakeholders.
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Response by the FIA European Principal Traders Association to the European Commission consultation on the draft Delegated Regulation specifying the conditions under which the commercial terms for clearing services for OTC derivatives are to be considered to be fair, reasonable, non-discriminatory and transparent (FRANDT)
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.
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FIA EPTA response to the Consultation Paper by ESMA on MiFID II/MiFIR review report on Algorithmic Trading
The FIA European Principal Traders Association (FIA EPTA) appreciates the opportunity to provide feedback to the European Securities and Markets Authority (ESMA) on the consultation on the impact of the requirements under MiFID II/MiFIR regarding algorithmic trading, including high-frequency algorithmic trading. Our members are independent market makers and providers of liquidity and risk transfer on trading venues and end-investors across Europe.
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Europe's algorithmic trading rules come under the microscope
FIA European Principal Traders Association (FIA EPTA) hosted a webinar on 24 February that reviewed European algorithmic trading rules under MiFID II and discussed suggestions put forward by the European Securities and Markets Authority (ESMA) for potential changes to the regime. Rules around algorithmic and high-frequency trading, as well as various aspects of market microstructure, form an important cornerstone of the MiFID II rulebook. In December 2020, ESMA published a consultation paper, evaluating the algorithmic trading regime ahead of the upcoming MiFID II Review by the European Commission. ESMA also made suggestions for potential new additions to the regime.
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