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EPTA Position Papers

  • 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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  • Response by FIA EPTA to the EBA consultation on Draft Regulatory Technical Standards on the reclassification of investment firms as credit institutions in accordance with Article 8a (6)(b) of Directive 2013/36/EU

    FIA EPTA welcomes the opportunity to respond to the EBA’s consultation paper (the Consultation Paper) on proposed revised Regulatory Technical Standards relating to the reclassification of investment firms as credit institutions in accordance with Article 8a(6)(b) of Directive 2013/36/EU (the Reclassification RTS). FIA EPTA has consistently welcomed the new prudential regime for investment firms contained in the Investment Firm Regulation and Directive (IFR/IFD), which is aimed at creating a tailored and proportionate prudential framework for firms such as those we represent.

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  • FIA EPTA Response to the Bank of England Consultation on the Derivatives clearing obligation

    FIA EPTA welcomes the opportunity to respond to the Bank of England on its proposal to amend the derivatives clearing obligation to reflect interest rate benchmark reform. FIA EPTA has consistently supported the G20 reforms to the OTC derivatives markets, which have made these markets more open, competitive, and transparent

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  • FIA EPTA response to UK Government (BEIS) consultation on “Restoring trust in audit and corporate governance.”

    FIA EPTA members are supportive of measures to enhance transparency, corporate governance, and good market conduct and are generally supportive of many provisions in the Consultation. However, we note below the areas where we have concerns and believe further work and public consultation would be needed in order for the UK to develop an appropriate, proportionate regime that supports good corporate governance, the reputation of the UK as a good place to do business, and the competitiveness of the UK economy

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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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  • Response by FIA EPTA to the FCA’s second Consultation Paper on a new UK prudential regime for MiFID investment firms

    The FIA European Principal Traders Association (FIA EPTA) appreciates the opportunity to provide feedback to the Financial Conduct Authority (FCA) on its second 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 (CP21/7).

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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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  • FIA EPTA Response to the HM Treasury Consultation on the Implementation of the Investment Firms Prudential Regime and Basel 3 standards

    The FIA European Principal Traders Association (FIA EPTA) appreciates the opportunity to respond to HM Treasury’s consultation on the Implementation of the Investment Firms Prudential Regime and Basel 3 standards. As MiFID II investment firms our members strongly support the more proportionate prudential regime contained in the Investment Firms Prudential Regime (IFPR). FIA EPTA members agree with the Government’s proposals. Specifically, in regard to the UK resolution regime, we would strongly urge the Government to exclude FCA authorised investment firms from its scope. We hope this feedback is useful and would be delighted to provide any further input as required.

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  • FIA EPTA response to the EBA Consultation on its Guidelines on internal governance for investment firms (EBA/CP/2020/27)

    FIA EPTA appreciates the opportunity to provide feedback to the European Banking Authority (EBA) Consultation on its Guidelines on internal governance for investment firms. FIA EPTA members note that the Draft EBA Guidelines on Internal Governance are very similar to those currently in effect and applicable to CRD V and MiFID firms, with relatively few changes.

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