FIA EPTA response to IOSCO Consultation Report CR04/22: Exchange Traded Funds – Good Practices for Consideration

6 July 2022

FIA EPTA appreciates the opportunity to comment on IOSCO’s proposed good practices, which we generally welcome. FIA EPTA supports open, fair, transparent and competitive markets. These principles have informed our responses. For example, we believe it is critical to ensure funds’ AP selection processes remain fair and open to new entrants, as this ultimately benefits end-investors and market resilience.

We also believe that uses of measures such as iNAV can reduce transparency and increase uncertainty versus the real-time public information that secondary ETF trading allows. We consider that reliance on iNAV is not recommended therefore and we would suggest that IOSCO may wish to disincentive use of the iNAV measure itself rather than focus on ancillary measures seeking to mitigate issues identified with it. This said, in the main we believe IOSCOs measures are sensible and also duly recognise that the ETF markets broadly continue to function effectively and have navigated recent periods of market stress well.

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