FIA EPTA response to the EBA Consultation Paper on Draft Guidelines on the application of the group capital test for investment firm groups (EBA/CP/202/16)
FIA EPTA response to the EBA’s Consultation Paper on Draft Guidelines on resubmission of historical data under the EBA reporting framework (EBA/CP/2023/06)
FIA EPTA welcomes the opportunity to respond to the EBA Consultation Paper on the Draft Guidelines on common procedures and methodologies for the supervisory review and evaluation process (SREP) under IFD. FIA EPTA members believe that the overarching principle of proportionality, which stems from the Level 1 legislation, should be applied across all topics covered in the Draft Guidelines and the elaboration of that principle in the regulation should be guaranteed.
FIA EPTA welcomes the opportunity to respond to the Financial Conduct Authority (FCA) Consultation Paper on Regulatory fees and levies: policy proposals for 2022/23. FIA EPTA does not have a strong view on the proposed change as in practice we are not aware of any firms subject to IFPR that have obtained in the past such internal model approval. This is due to the fact that the conditions to implement the internal model are extremely burdensome as they were initially designed for large credit institutions. However, should the FCA allow for a relaxation of these conditions at some point in time
FIA EPTA appreciates the opportunity to provide feedback to the Financial Conduct Authority (FCA) on its third Consultation Paper regarding the implementation of the new UK prudential regime for MiFID investment firms. This document constitutes FIA EPTA’s response to the FCA’s Consultation Paper on a new UK prudential regime for MiFID investment firms (CP21/26). We welcome the FCA’s approach as set out in the Consultation Paper and agree that the FCA’s proposed rules are clear, proportionate and fit for purpose. In our response, we focus only on a limited number of areas where we believe further improvements or clarifications could be made to enable a proportionate, effective and practicable prudential regime for investment firms.
FIA EPTA welcomes the opportunity to comment on the Basel Committee Consultative Document “Prudential treatment of cryptoasset exposures”, dated June 2021. The discussions within the Basel Committee and this Consultative Document are very timely. We have reached a pivotal moment for the adoption of innovative technologies that will improve capital markets by verifiable and transparent information, higher efficiency of clearing and settlement and more liquidity. New digital assets are emerging that promise greater stability, wider acceptance and increase possible uses.
FIA EPTA welcomes the opportunity to respond to the EBA’s consultation paper (the Consultation Paper) on proposed revised Regulatory Technical Standards relating to the reclassification of investment firms as credit institutions in accordance with Article 8a(6)(b) of Directive 2013/36/EU (the Reclassification RTS). FIA EPTA has consistently welcomed the new prudential regime for investment firms contained in the Investment Firm Regulation and Directive (IFR/IFD), which is aimed at creating a tailored and proportionate prudential framework for firms such as those we represent.
FIA EPTA members are supportive of measures to enhance transparency, corporate governance, and good market conduct and are generally supportive of many provisions in the Consultation. However, we note below the areas where we have concerns and believe further work and public consultation would be needed in order for the UK to develop an appropriate, proportionate regime that supports good corporate governance, the reputation of the UK as a good place to do business, and the competitiveness of the UK economy
The FIA European Principal Traders Association (FIA EPTA) appreciates the opportunity to provide feedback to the Financial Conduct Authority (FCA) on its second Consultation Paper regarding the implementation of the new UK prudential regime for MiFID investment firms. This document constitutes FIA EPTA’s response to the FCA’s Consultation Paper on a new UK prudential regime for MiFID investment firms (CP21/7).
The FIA European Principal Traders Association (FIA EPTA) appreciates the opportunity to respond to HM Treasury’s consultation on the Implementation of the Investment Firms Prudential Regime and Basel 3 standards. As MiFID II investment firms our members strongly support the more proportionate prudential regime contained in the Investment Firms Prudential Regime (IFPR). FIA EPTA members agree with the Government’s proposals. Specifically, in regard to the UK resolution regime, we would strongly urge the Government to exclude FCA authorised investment firms from its scope. We hope this feedback is useful and would be delighted to provide any further input as required.
FIA EPTA appreciates the opportunity to provide feedback to the European Banking Authority (EBA) Consultation on its Guidelines on internal governance for investment firms. FIA EPTA members note that the Draft EBA Guidelines on Internal Governance are very similar to those currently in effect and applicable to CRD V and MiFID firms, with relatively few changes.
FIA EPTA appreciates the opportunity to provide feedback to the European Banking Authority (EBA) Consultation on its Guidelines on remuneration policies for investment firms. FIA EPTA members note that the Draft EBA Guidelines on sound remuneration policies are very similar to the Guidelines EBA/GL/2015/22 dated 21 December 2015 currently in effect and applicable to firms subject to CRD V and MiFID firms, with minimal changes.
FIA EPTA response to the European Banking Authority (EBA) Consultation Paper on the Draft Regulatory Technical Standards on the specific liquidity measurement for investment firms
FIA EPTA response to the European Banking Authority (EBA) Consultation Paper on the Draft Guidelines on common procedures and methodologies for the supervisory review and evaluation process (SREP) under IFD
