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  • FIA EPTA response to the ESMA Consultation Paper on ESMA’s Opinion on the trading venue perimeter

    FIA EPTA appreciates the opportunity to provide feedback to the European Securities and Markets Authority (ESMA) on the consultation on ESMA’s Opinion on the trading venue perimeter. FIA EPTA considers that ESMA’s approach to defining multilateral systems is overly broad and risks creating further confusion and inconsistencies in the application of MiFID II across the Union.

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  • FIA EPTA response on the BaFin Consultation on a planned General Administrative Act regarding Futures with additional payment obligations

    FIA EPTA members would like to emphasise that we value and support the objective by BaFin to prioritise investor protection. We agree that it is of the utmost importance to ensure that financial markets are transparent and safe for retail investors. However, as said, we do not consider that banning listed futures trading for retail investors, as now proposed by BaFin, will contribute to this objective, and in our view rather the opposite.

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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 EPTA response to the IOSCO Consultation Paper on Operational resilience of trading venues and market intermediaries during the COVID-19 pandemic

    FIA EPTA welcomes the opportunity to respond to the IOSCO Consolation Paper on the Operational resilience of trading venues and market intermediaries during the COVID-19 pandemic. FIA EPTA members believe it an important step by IOSCO to review the resilience of financial market participants during the Covid-19 pandemic as the lessons learned will better prepare the sector for future occurrences of high volatility.

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  • FIA EPTA response to the ESMA Call for Evidence On Market Characteristics for ESG Rating Providers in the EU

    FIA EPTA welcomes the opportunity to respond to the European Securities and Markets Authority (ESMA) Call for Evidence On Market Characteristics for ESG Rating Providers in the EU. In 2019 FIA EPTA established a Sustainable Finance Committee for its member firms to explore how liquidity providers can contribute to the green transition. FIA EPTA members believe ESG ratings are extremely relevant for EU financial markets and financial market participants.

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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 ESMA CfE on the DLT pilot regime

    FIA EPTA welcomes the opportunity to respond to the European Securities and Markets Authority (ESMA) Call for Evidence on the DLT Pilot Regime. FIA EPTA believes it is an important step by ESMA to review the DLT space as it will grow in use and importance. Over the past years, FIA ETPA Members have become increasingly active in the Digital Assets space and several members have become liquidity providers in this new and developing market.

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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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