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Market Structure

Global derivatives markets function best when principles-based regulation can be applied across jurisdiction with as little cross-border friction as possible, allowing efficient price-discovery and fair competition.

FIA publishes China netting and collateral legal opinions

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  • Trade associations call for clarity on EMIR 3.0 effective implementation dates

    FIA, AIMA, EBF, EFAMA and ISDA have sent a letter urging the European Commission and European Supervisory Authorities to clarify that market participants are not required to implement the European Market Infrastructure Regulation (EMIR 3.0) Level 1 provisions prior to the date of application of the associated Level 2 regulatory technical standards (RTS).

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  • FIA responds to CFTC proposed rulemaking on FCM separate account margining

    FCMs are currently relying on no-action relief that allows them to separately margin accounts of the same beneficial owner. This rule marks the second attempt by the CFTC to codify that relief. FIA’s letter asks the CFTC to codify the relief as written without laying on additional highly prescriptive requirements that limit FCM discretion to risk manage accounts.

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  • FIA responds to CFTC Foreign Boards of Trade proposed rulemaking

    Under current rules, US-based commodity pool operators, commodity trading advisers, futures commission merchants and prop firms can directly access Foreign Boards of Trade. The pending rule would include US-based introducing brokers among the permissioned registrants. FIA’s letter supports the proposed expansion, noting that adding introducing brokers to the mix should provide more brokerage options for US customers and promote liquidity in foreign products.

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  • FIA responds to FICC access and segregation proposals

    FIA has responded to the Fixed Income Clearing Corporation’s proposals to revise its customer clearing access models and to modify its margin segregation rules in order to implement the SEC’s new clearing mandate for U.S. Treasuries. FIA's response identifies conflicts between the proposed access structures and CFTC rules to which FCMs are subject.

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