FIA supports replacing the market share test with an annual threshold test, but raises concerns about the suggested inclusion of trading venue activity. Doing so would add complexity, increase compliance costs, and reduce UK competitiveness relative to the EU and the US, where only non-venue derivatives are counted.
FIA, ISDA and SIFMA strongly support the proposed recalibration of the Enhanced Supplementary Leverage Ratio and urge the Federal Reserve, FDIC, and OCC to finalize the proposal as soon as possible, with an effective date no later than 1 January 2026.
The Joint Trades recommend essential revisions of the Basel banking prudential treatment of cryptoassets and pausing implementation of SCO60 ahead of its January 2026 effective date to allow for a targeted consultation and redesign. The letter highlights the excessively conservative and overly punitive capital treatment of cryptoassets that is misaligned with actual risks, in addition to various inconsistencies with current market risk management practices.
FIA has responded to the US Commodity Futures Trading Commission’s spot crypto listing initiative, which invites stakeholders to work with the Commission “on providing regulatory clarity on how to list spot crypto asset contracts on CFTC-regulated designated contract markets” using the Commission’s “existing authority” under the Commodity Exchange Act.
FIA and ISDA urge greater clarity in the RBA’s draft guidance on clearing and settlement facility resolution to enhance transparency, communication and market stability during interventions.
The Senate Banking Committee published its version of proposed legislation on market structure and digital assets and issued a request for information. FIA has responded with its views, including commentary on the role of the CFTC, the importance of market intermediaries, and other topics.
FIA has responded to the Montreal Exchange's consultation on its approved persons regime. Approved persons on TMX are essentially the individuals permitted to trade on the exchange.
The digital asset industry deserves and requires a proper regulatory framework that will keep these markets safe, innovative and growing. The US has an opportunity to lead in the global development of digital assets, but Congress must act quickly. Without this leadership, these markets will continue to expand overseas and outside of the reach of US influence.
The response notes it is essential to take into account how a specific market is being used by understanding the central limit order book and the size of business that can be executed in that order book in a short amount of time without causing price slippage. Moreover, it is important to distinguish between ETD and OTC product specificities.
