FIA filed comments with the US Securities and Exchange Commission responding to ICE Clear Credit's proposed US Treasury clearing rules. The letter commends ICC for its efforts to expand its clearing services to the U.S. Treasury market and recommends refinements to certain aspects of the proposed rules to ensure predictability and clarity for clearing firms and market participants that will participate on ICC's platform, once approved.
FIA appreciates the opportunity to provide feedback to the European Central Bank (ECB) Consultation Paper on the extension of T2 (formerly TARGET 2) operating hours. In the short term, FIA Members suggest moving to a 23 hours / 5 days a week T2 payment settlement model for use on a voluntary basis, with the T2 closing window being reduced to one hour.
FIA submitted a petition to the Commodity Futures Trading Commission to sunset its Part 20 regulations for large trader reporting for physical commodity swaps. Issued in 2011 as a temporary swaps data collection measure, the CFTC has since established a comprehensive reporting regime for swaps through a series of rulemakings that has rendered the Swaps LTR Rules redundant and unnecessary.
FIA has responded to the European Securities and Markets Authority’s Call for Evidence seeking industry input on simplifying regulatory reporting requirements in the European Union. FIA highlights industry concerns with current requirements and provide ways in which the burden on market participants can be reduced without impacting the quality and usability of data used by regulatory authorities for the oversight of systemic risk and the detection of market abuse.
FIA has responded to the European Securities and Markets Authority’s consultation on margin transparency requirements, urging the regulator not to mandate overly prescriptive requirements for clearing member firms, particularly those that do not apply their own margin models but simply pass through clearinghouses’ margin requirements to clients.
FIA has submitted comments to the Securities and Exchange Board of India on its proposal to introduce a closing auction session in the equity cash segment. FIA welcomes SEBI’s initiative as an important step in bringing India’s market structure closer to global best practices.
FIA has submitted a response to the European Securities and Markets Authority’s consultation paper on clearing fees and associated costs information under the European Market Infrastructure Regulation (EMIR 3.0). FIA cautions against the proposed requirements on clearing service providers, which are duplicative, and suggests an alternative approach.
FIA has submitted its response to the Securities and Exchange Board of India’s consultation on the implementation of eligibility criteria for derivatives on non-benchmark indices, which aim to prevent concentration of derivatives indices in a few stocks. FIA supports Alternative B, which allows existing indices to transition through reweighting and constituent adjustments, rather than requiring the creation of entirely new indices.
FIA, ISDA and the European Fund and Asset Management Association have shared a paper with EU policymakers, requesting clarification on the implementation of the active account requirement under the European Market Infrastructure Regulation (EMIR 3.0) in relation to representativeness. The associations request regulatory guidance, with a view to standardising compliance and avoiding fragmented implementation of requirements across EU member states.
FIA has submitted its response to ASX on its proposed Dynamic Default Fund Framework. In its response, FIA welcomed the initiative to strengthen resilience and risk management and also urged refinements to better align with international standards and market practice.
