Prudential Regulation

FIA EPTA has responded to a European Banking Authority consultation regarding draft guidelines on the sound management of third-party risk with regard to non-ICT related services. FIA EPTA members support robust risk management and the EBA’s efforts toward the enhancement of operational resilience. However, we have significant concerns regarding the proposal’s legal basis, proportionality, misalignment with the EU simplification and growth agenda, and the EBA’s cost-benefit analysis. CONTINUE READING

FIA EPTA has responded to HM Treasury and to the Financial Conduct Authority in parallel consultations on reforms to the Senior Managers & Certification Regime. FIA EPTA members strongly support reform of the SMCR as a unique opportunity to support the UK’s competitiveness and growth objectives. CONTINUE READING

FIA EPTA has released its policy recommendations for 2024-29, under the title Tide of Change: Enhancing Liquidity Provision to the European Economy. The EU urgently needs to bolster its capital markets to achieve its strategic objectives for a safe, green and prosperous future for its citizens. To grasp the opportunities ahead and ensure the success of the Savings and Investment Union, the EU needs capital markets with deep and diverse liquidity. CONTINUE READING

FIA EPTA welcomes the opportunity to respond to the EBA’s Discussion Paper on the Call for Advice on the Investment Firms Prudential Framework (DP). We note that this DP offers limited discussion points and suggests many proposals for changes with no associated questions. We also believe that these proposed changes intend to borrow further requirements and methodologies existing in CRR. CONTINUE READING

FIA EPTA welcomes the objective of the EBA to ensure a harmonized interpretation and implementation of the Group Capital Test (“GCT”) by setting objective criteria to assess whether the structure of an investment firm group is: a) sufficiently simple, and b) poses significant risks to clients or to market. We agree that it is indeed important to ensure a level playing field in the application of the regime across the EU and important to provide guidelines to NCAs for them to supervise investments firms in an efficient manner. CONTINUE READING

FIA EPTA is broadly supportive of the laid-out draft guidelines on the resubmission of historical data and welcome the clarity it provides. We are however concerned that the numerical materiality thresholds (tolerance limits) outlined in paragraph 18 would result in a large volume of historical data resubmission for the vast majority of entities covered by these guidelines.  CONTINUE READING