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EPTA Position Papers

  • 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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  • FIA EPTA response to the EBA Consultation on Guidelines on remuneration policies for investment firms (EBA/CP/2020/26)

    FIA EPTA appreciates the opportunity to provide feedback to the European Banking Authority (EBA) Consultation on its Guidelines on remuneration policies for investment firms. FIA EPTA members note that the Draft EBA Guidelines on sound remuneration policies are very similar to the Guidelines EBA/GL/2015/22 dated 21 December 2015 currently in effect and applicable to firms subject to CRD V and MiFID firms, with minimal changes.

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  • FIA EPTA response to the Consultation Paper by ESMA on MiFID II/MiFIR review report on Algorithmic Trading

    The FIA European Principal Traders Association (FIA EPTA) appreciates the opportunity to provide feedback to the European Securities and Markets Authority (ESMA) on the consultation on the impact of the requirements under MiFID II/MiFIR regarding algorithmic trading, including high-frequency algorithmic trading. Our members are independent market makers and providers of liquidity and risk transfer on trading venues and end-investors across Europe.

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  • FIA EPTA & FIA PTG Response to the Call for Evidence by HM Treasury on the UK’s Overseas Framework

    The FIA European Principal Traders Association (FIA EPTA) and the FIA Principal Traders Group (FIA PTG) appreciate the opportunity to respond to HM’s Treasury Call for Evidence on the UK’s Overseas Framework. FIA EPTA and FIA PTG are supportive of HM Treasury’s current overseas framework and the call to provide industry insight on how to continue and create flexible approaches for non-UK firms to access various UK markets and exchanges.

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  • 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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