Publications & Filings
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FIA asks CFTC to sunset large trader reporting for commodity swaps
FIA, joined by ISDA, has responded to the CFTC’s notice of intent to renew the collection of large trader reporting (LTR) data for physical commodity swaps. The associations reiterate and build on requests they have made in recent years for the CFTC to sunset the LTR rules for swaps, which were envisioned as a temporary measure while the CFTC stood up its comprehensive swap reporting framework under Dodd-Frank.
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FIA responds to FCA proposal on publicising enforcement investigations
FIA has responded to the UK Financial Conduct Authority’s public consultation on changes to its approach to enforcement investigations. The proposed changes include the FCA publicly announcing the opening of an investigation and disclosing the identity of the subject of the investigation where it considers this to be in the public interest. FIA is concerned that the proposed approach will be detrimental to the orderly functioning of UK capital markets, with limited value to public interest.
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FIA cautions CFTC on regulation of AI
FIA has urged the CFTC to take a "technology-neutral" approach and focus on "outcomes and use cases" rather than the technology itself. FIA also urged the CFTC to consider the applicability of its existing rules and regulations before presupposing that new, AI-specific regulations are needed.
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FIA responds to CFTC proposed rulemaking on FCM separate account margining
FCMs are currently relying on no-action relief that allows them to separately margin accounts of the same beneficial owner. This rule marks the second attempt by the CFTC to codify that relief. FIA’s letter asks the CFTC to codify the relief as written without laying on additional highly prescriptive requirements that limit FCM discretion to risk manage accounts.
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FIA responds to CFTC Foreign Boards of Trade proposed rulemaking
Under current rules, US-based commodity pool operators, commodity trading advisers, futures commission merchants and prop firms can directly access Foreign Boards of Trade. The pending rule would include US-based introducing brokers among the permissioned registrants. FIA’s letter supports the proposed expansion, noting that adding introducing brokers to the mix should provide more brokerage options for US customers and promote liquidity in foreign products.
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FIA responds to FICC access and segregation proposals
FIA has responded to the Fixed Income Clearing Corporation’s proposals to revise its customer clearing access models and to modify its margin segregation rules in order to implement the SEC’s new clearing mandate for U.S. Treasuries. FIA's response identifies conflicts between the proposed access structures and CFTC rules to which FCMs are subject.
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FIA responds to JSCC consultation on initial margin and clearing fund calculation methods
FIA has submitted a response to the Japan Securities Clearing Corporation’s consultation, which proposes to introduce stress add-on initial margin charges and a partial revision of the clearing fund calculation method in its listed financial derivatives clearing service.
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FIA calls on international regulators to continue progress on margin transparency
FIA has filed a letter with international standard-setting bodies urging further progress on efforts to increase the resilience of global derivatives markets in times of stress. The letter was submitted in response to a consultation on initial margin requirements in centrally cleared derivatives markets that was issued by Basel Committee on Banking Supervision (BCBS), the Bank for International Settlements' Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO).
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European T+1 Industry Task Force responds to UK report
FIA has joined several industry associations in welcoming a recent UK report on moving to T+1 settlement.
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FIA responds to CFTC proposal on FCM operational resilience framework
FIA has submitted a response to the CFTC’s proposed rule requiring an operational resilience framework for futures commission merchants.
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