Prudential Regulation
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Tide of Change: Enhancing Liquidity Provision to the European Economy
FIA EPTA has released its policy recommendations for 2024-29, under the title Tide of Change: Enhancing Liquidity Provision to the European Economy. The EU urgently needs to bolster its capital markets to achieve its strategic objectives for a safe, green and prosperous future for its citizens. To grasp the opportunities ahead and ensure the success of the Savings and Investment Union, the EU needs capital markets with deep and diverse liquidity.
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FIA EPTA response to the EBA’s Discussion Paper on the Commission’s Call for Advice on the Investment Firms Prudential Framework
FIA EPTA welcomes the opportunity to respond to the EBA’s Discussion Paper on the Call for Advice on the Investment Firms Prudential Framework (DP). We note that this DP offers limited discussion points and suggests many proposals for changes with no associated questions. We also believe that these proposed changes intend to borrow further requirements and methodologies existing in CRR.
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FIA EPTA response to the EBA Consultation Paper on Draft Guidelines on the application of the group capital test for investment firm groups (EBA/CP/202/16)
FIA EPTA welcomes the objective of the EBA to ensure a harmonized interpretation and implementation of the Group Capital Test (“GCT”) by setting objective criteria to assess whether the structure of an investment firm group is: a) sufficiently simple, and b) poses significant risks to clients or to market. We agree that it is indeed important to ensure a level playing field in the application of the regime across the EU and important to provide guidelines to NCAs for them to supervise investments firms in an efficient manner.
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FIA EPTA response to the EBA’s Consultation Paper on Draft Guidelines on resubmission of historical data under the EBA reporting framework (EBA/CP/2023/06)
FIA EPTA is broadly supportive of the laid-out draft guidelines on the resubmission of historical data and welcome the clarity it provides. We are however concerned that the numerical materiality thresholds (tolerance limits) outlined in paragraph 18 would result in a large volume of historical data resubmission for the vast majority of entities covered by these guidelines.
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FIA EPTA response to the EBA CP on Draft Guidelines on the benchmarking of diversity practices including diversity policies and gender pay gap
Although FIA EPTA members agree that transparency in general, and more specifically benchmarking, will contribute to achieving these objectives, we are of the opinion that especially the level of detail of the questions regarding the diversity policies are not appropriate in the light of these objectives and/ or need further clarifications.
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FIA EPTA response to the EBA Discussion Paper on the role of Environmental Risks in the Prudential Framework
FIA EPTA welcomes the opportunity to respond to the European Banking Authority (EBA) Discussion Paper on the role of Environmental Risks in the Prudential Framework. In 2019 FIA EPTA established a Sustainable Finance Committee for its member firms to explore how liquidity providers can contribute to the green transition. It is FIA EPTA’s view that sustainable finance offers a great promise in unlocking investment capital that is essential for fighting climate change and mitigating its impact for citizens.
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FIA EPTA response to the EBA CP on the Draft Regulatory Technical Standards on the specific liquidity measurement for investment firms
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.
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FIA EPTA Response to the EBA Consultation Paper on the Draft RTS on Pillar 2 add-ons for investment firms under Article 40(6) of Directive (EU) 2019/2034
FIA EPTA welcomes the opportunity to respond to the EBA Consultation Paper on the Draft Regulatory Technical Standards on Pillar 2 add-ons for investment firms under Article 40(6) of Directive (EU) 2019/2034. FIA EPTA is concerned about the fact that art. 4(2) of the draft Delegated Regulation effectively creates a floor with respect to the additional Pillar 2 requirements. This is the result of the fact that the additional own funds requirements as calculated in art. 4(1) are to express both (1) as an absolute amount, as well as (2) as the ratio of that amount to own funds requirements.
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FIA EPTA response to the EBA Consultation Paper on the Draft Guidelines on common procedures and methodologies for the SREP under IFD
FIA EPTA welcomes the opportunity to respond to the EBA Consultation Paper on the Draft Guidelines on common procedures and methodologies for the supervisory review and evaluation process (SREP) under IFD. FIA EPTA members believe that the overarching principle of proportionality, which stems from the Level 1 legislation, should be applied across all topics covered in the Draft Guidelines and the elaboration of that principle in the regulation should be guaranteed.
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FIA EPTA response to the Financial Conduct Authority (FCA) Consultation Paper on Regulatory fees and levies: policy proposals for 2022/23
FIA EPTA welcomes the opportunity to respond to the Financial Conduct Authority (FCA) Consultation Paper on Regulatory fees and levies: policy proposals for 2022/23. FIA EPTA does not have a strong view on the proposed change as in practice we are not aware of any firms subject to IFPR that have obtained in the past such internal model approval. This is due to the fact that the conditions to implement the internal model are extremely burdensome as they were initially designed for large credit institutions. However, should the FCA allow for a relaxation of these conditions at some point in time
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