March 11, 2021
• EPTA, FIA European Principal Traders Association, Market Structure, FIA Principal Traders Group, Cross Border, Advocacy, UK, Advocacy, Position Papers
The FIA European Principal Traders Association (FIA EPTA) and the FIA Principal Traders Group (FIA PTG) appreciate the opportunity to respond to HM’s Treasury Call for Evidence on the UK’s Overseas Framework. FIA EPTA and FIA PTG are supportive of HM Treasury’s current overseas framework and the call to provide industry insight on how to continue and create flexible approaches for non-UK firms to access various UK markets and exchanges.
The FIA European Principal Traders Association (FIA EPTA) welcomes the opportunity to respond to the International Organization of Securities Commissions (IOSCO) Consultation Report on market data in the secondary equity markets. In today’s markets, market data is of crucial importance for a wide range of investors and market participants – including FIA EPTA member firms.
On 2 February 2021, ISDA, FIA and FIA EPTA submitted a joint response to the European Commission’s (EC) targeted consultation on the review of the settlement and central securities depositories regulation (CSDR). The Associations outline their members’ concerns with regards to detrimental effects arising from the application of the CSDR mandatory buy-in regime for derivatives markets. The Associations request the European Commission and the co-legislators to clarify that the mandatory buy-in requirements of the CSDR settlement discipline regime do not apply in the context of margin transfers, physically settled derivatives and emission allowances.
FIA EPTA members welcome the opportunity to respond to this Consultation Paper on Guidelines on the MiFID II/ MiFIR obligations on market data. FIA EPTA has consistently supported ESMA’s work on market data issues and we very much welcomed ESMA’s review report from December 2019 and its draft Guidelines which build on this report. As we have shown in our response to ESMA’s previous consultation in 2019, user data fees are high and have increased over the past years.
FIA EPTA welcomes the opportunity to respond to the FCA Call for Input on accessing and using wholesale data. Below, we respond to the FCA’s questions in relation to trading data, benchmarks and market data vendor services. FIA EPTA members observe that user data fees are high and have increased over the past years. Empirical data which we have analysed substantiates this. We also observe that new fees have been added and that market data policies and agreements are increasingly complex.
