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Prudential Regulation

  • FIA EPTA response to the EBA Consultation Paper on Draft Guidelines on the application of the group capital test for investment firm groups (EBA/CP/202/16)

    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.

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  • FIA EPTA response to the EBA’s Consultation Paper on Draft Guidelines on resubmission of historical data under the EBA reporting framework (EBA/CP/2023/06)

    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. 

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  • FIA EPTA response to the EBA CP on Draft Guidelines on the benchmarking of diversity practices including diversity policies and gender pay gap

    Although FIA EPTA members agree that transparency in general, and more specifically benchmarking, will contribute to achieving these objectives, we are of the opinion that especially the level of detail of the questions regarding the diversity policies are not appropriate in the light of these objectives and/ or need further clarifications.

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  • FIA EPTA response to the EBA Discussion Paper on the role of Environmental Risks in the Prudential Framework

    FIA EPTA welcomes the opportunity to respond to the European Banking Authority (EBA) Discussion Paper on the role of Environmental Risks in the Prudential Framework. In 2019 FIA EPTA established a Sustainable Finance Committee for its member firms to explore how liquidity providers can contribute to the green transition. It is FIA EPTA’s view that sustainable finance offers a great promise in unlocking investment capital that is essential for fighting climate change and mitigating its impact for citizens.

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