FIA EPTA members would like to emphasise that we value and support the objective by BaFin to prioritise investor protection. We agree that it is of the utmost importance to ensure that financial markets are transparent and safe for retail investors. However, as said, we do not consider that banning listed futures trading for retail investors, as now proposed by BaFin, will contribute to this objective, and in our view rather the opposite.
FIA EPTA members believe that the Commission should firstly focus on opportunities to incentivise clearing of new transactions on EU CCPs as moving legacy positions to another CCP will create issues around higher cost and increased risk of closing and re-opening the cleared position on the market. FIA EPTA members believe that harmonisation of the different EU legal frameworks for cross-border activity would be helpful as EU CCPs require complex legal structures to ensure the enforceability of their rules in a default situation.
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 appreciates the opportunity to provide feedback to the European Securities and Markets Authority (ESMA) on the call for evidence On the European Commission mandate on certain aspects relating to retail investor protection. FIA EPTA considers that regulatory measures should be taken to encourage and highlight the benefits of exchange-listed products.
FIA EPTA welcomes the opportunity to respond to ESMA Consultation Paper on Review of the MiFID II framework on best execution reports. FIA EPTA would welcome the opportunity to provide further background to ESMA on the issues raised in our response. FIA EPTA agrees with the proposed change in scope of execution venues i.e. that execution venues for the purpose of the best execution reporting regime for execution venues (RTS 27) should not include ‘market makers’.
FIA EPTA appreciates the opportunity to provide feedback to the European Securities and Markets Authority (ESMA) on the consultation on the review of certain aspects of the Short Selling Regulation. FIA EPTA is of the view that short-selling bans are harmful to the orderly functioning of markets. We note the unnecessary operational risks that were a consequence of short selling bans implemented inconsistently and with limited lead-time last year.
The ability of independent market making firms to provide essential liquidity to Europe’s pension funds and other asset managers during the Covid-19 financial crisis has accelerated their recognition as a vital part of the European capital markets eco-system. A new research report surveying European buyside participants reveals for the first time how market makers stepped up to help the asset managers when some of the traditional providers of risk capital partially withdrew from certain market segments in Europe in the early stages of the pandemic.
The FIA European Principal Traders Association (FIA EPTA) appreciates the opportunity to provide feedback to the HM Treasury Consultation Paper regarding the Wholesale Markets Review.
FIA EPTA agrees that the breadth of the current definition of a ‘multilateral system’ has created ambiguity about the regulatory perimeter which should be clarified. This has been particularly acute for brokers arranging transactions over the phone (so called “voice brokers”) and technology firms innovating new ways of bringing together buying and selling interests.
The FIA European Principal Traders Association (FIA EPTA) appreciates the opportunity to provide feedback to the European Securities and Markets Authority (ESMA) to the Consultation Paper on the clearing and derivative trading obligations in view of the benchmark transition. We encourage ESMA to incorporate ongoing flow trading data into its analysis. Data regarding daily trading activity is important when making liquidity assessments and monitoring the market’s ongoing transition to new benchmark rates.
FIA EPTA welcomes the opportunity to respond to the European Commission’s consultation on permanently lowering the relevant threshold for the notification of significant net short positions in shares. Short selling plays an important role in ensuring the proper functioning of financial markets in terms of liquidity and efficiency of price formation. It enables investors to manage risk and marketmakers to facilitate risk transfer for others by hedging their positions through buying and selling shares.
