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EPTA Position Papers

  • FIA EPTA response to the IOSCO consultation on Market Data in the Secondary Equity Markets (CR03/2020)

    The FIA European Principal Traders Association (FIA EPTA) welcomes the opportunity to respond to the International Organization of Securities Commissions (IOSCO) Consultation Report on market data in the secondary equity markets. In today’s markets, market data is of crucial importance for a wide range of investors and market participants – including FIA EPTA member firms.

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  • Response by FIA EPTA to the FCA Consultation Paper on a 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 (CP20/24). We very much welcome the FCA’s approach as set out in the Consultation Paper and generally agree that the FCA’s proposed rules are clear, proportionate and fit for purpose. In our response, we focus on a number of key areas where we believe further improvements or clarifications could be made to enable a proportionate, effective and practicable prudential regime for investment firms.

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  • FIA EPTA response to the EBA Discussion Paper on management and supervision of ESG risks for credit institutions and investment firms

    FIA EPTA is committed to supporting policymakers in ensuring the success of the sustainable finance project at all levels of the capital market ecosystem. The consultation that the EBA has published mainly focuses on ESG risks stemming from clients and counterparties. FIA EPTA members deal with regulated parties as counterparties, perform additional screenings that may already include the necessary ESG elements, and do not have clients or manage funds, but trade on their own account and at their own risk.

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  • FIA EPTA, FIA and ISDA offer joint response to the European Commission targeted consultationon the CSDR reviw

    On 2 February 2021, ISDA, FIA and FIA EPTA submitted a joint response to the European Commission’s (EC) targeted consultation on the review of the settlement and central securities depositories regulation (CSDR). The Associations outline their members’ concerns with regards to detrimental effects arising from the application of the CSDR mandatory buy-in regime for derivatives markets. The Associations request the European Commission and the co-legislators to clarify that the mandatory buy-in requirements of the CSDR settlement discipline regime do not apply in the context of margin transfers, physically settled derivatives and emission allowances.

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  • FIA EPTA response to the ESMA Consultation Paper on Guidelines on the MiFID II/MiFIR obligations on market data

    FIA EPTA members welcome the opportunity to respond to this Consultation Paper on Guidelines on the MiFID II/ MiFIR obligations on market data. FIA EPTA has consistently supported ESMA’s work on market data issues and we very much welcomed ESMA’s review report from December 2019 and its draft Guidelines which build on this report. As we have shown in our response to ESMA’s previous consultation in 2019, user data fees are high and have increased over the past years.

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  • FIA EPTA response to the FCA Call for Input on accessing and using wholesale data

    FIA EPTA welcomes the opportunity to respond to the FCA Call for Input on accessing and using wholesale data. Below, we respond to the FCA’s questions in relation to trading data, benchmarks and market data vendor services. FIA EPTA members observe that user data fees are high and have increased over the past years. Empirical data which we have analysed substantiates this. We also observe that new fees have been added and that market data policies and agreements are increasingly complex.

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  • FIA EPTA response to the FCA’s consultation paper on its approach to international firms

    The FIA European Principal Traders Association (FIA EPTA) appreciates the opportunity to respond to the FCA’s consultation paper on its approach to international firms and the process for setting out the FCA’s expectations of such firms operating in the United Kingdom under its framework. FIA EPTA is supportive of the FCA’s proposed flexible approach to the regulation of international firms.

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  • Response by the FIA EPTA to the ESMA consultation on MiFID II/ MiFIR review on the functioning of Organised Trading Facilities (OTF)

    FIA EPTA supports transparent, robust, and safe markets with a level playing field and appropriate regulation for market participants. We consistently support the aim of the market structure reforms laid out in MiFID II/MiFIR and welcome the opportunity to respond to this consultation on MiFID II/ MiFIR review on the functioning of Organised Trading Facilities (OTF). Our members are aware of various systems and market practices which seem to conflict with MiFID II expectations for multilateral systems.

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  • Response by FIA EPTA to the ESMA consultation on MiFIR review report on the obligations to report transactions and reference data

    FIA EPTA supports transparent, robust and safe markets with a level playing field and appropriate regulation for market participants. We consistently support the aim of the market structure reforms laid out in MiFID II/MiFIR and welcome the opportunity to respond to this consultation on the obligations to report transactions and reference data.

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  • Higher cost, higher risk: The impact of the closed market structure on the European warrants market: price analysis and recommendations

    In June 2020, FIA EPTA conducted research on the impact of the single liquidity provider structure on the European warrants market and compared it with the listed options market. We examined the pricing of comparable warrants and options products with matching risk/reward profiles and the impact of differing market conditions on investors’ ability to trade in both markets. The conclusions of this research are clear: investors trading on Europe’s warrants markets are losing millions of euros a year because of its ‘closedshop’ structure which inflates prices compared to comparable products on more open and competitive markets.

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