FIA EPTA welcomes the opportunity to respond to the IOSCO Consolation Paper on the Operational resilience of trading venues and market intermediaries during the COVID-19 pandemic. FIA EPTA members believe it an important step by IOSCO to review the resilience of financial market participants during the Covid-19 pandemic as the lessons learned will better prepare the sector for future occurrences of high volatility.
FIA EPTA members agree with the IOSCO assessment of the risks and challenges faced by regulated entities in the consultation paper. However, FIA EPTA members consider there to be additional risks and challenges that are not being mentioned in the consultation. This includes, Short-selling bans, Issues with dividend uncertainties, Exchanges outages and the Current Exposure Method and the adoption of SA-CCR.
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