Market Structure
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FIA EPTA response to the HM Treasury Call for Evidence on the Short Selling Regulation review
FIA EPTA welcomes the opportunity to respond to the HM Treasury Call for Evidence on the UK Short Selling Regulation. We are very supportive of HMT’s statements regarding the important role short selling plays in the efficient functioning of financial markets and see a great opportunity to bring about pragmatic reform of the UK Short Selling Regulation.
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FIA EPTA’s Response to ESMA’s Consultation Paper on Market Outages
FIA EPTA members are supportive of the work being done by ESMA on market outages, particularly efforts to require trading venues to publish clear comprehensive outages plans on an ex-ante basis. Market resilience is at the core of efficient and competitive financial markets and it is imperative that trading venues clearly outline a well-planned approach to communication and management in the event of a market outage to provide certainty to market participants.
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FIA EPTA response to CP 22/18 on Guidance on the trading venue perimeter
FIA EPTA appreciates the opportunity to respond to the FCA’s Consultation Paper 22/18 on Guidance on the trading venue perimeter. FIA EPTA memberswelcome the FCA’s proposed guidance and are generally in agreement with the FCA’s intended approach the FCA, which we consider to be proportionate and providing for an appropriate degree of clarity to market participants regarding whether the FCA would characterise a specific system as multilateral or not.
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FIA EPTA response to ESMA’s Call for Evidence on Pre-hedging (ESMA70-449-672)
FIA EPTA welcomes ESMA’s intention to provide more clarity, via future Level 3 guidance, regarding pre-hedging practices in RFQ markets. European RFQ markets have seen significant growth and development over the past years and we believe clarity on the situations where pre-hedging may be inappropriate (or not) will contribute to the greater efficiency and reliability of these markets for all participants.
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FIA EPTA response to the FCA’s CP22/12 on Improving Equity Secondary Markets
FIA EPTA is appreciative to the FCA for taking the lead in designing an improved post-trade transparency regime which should benefit the efficiency and competitiveness of UK capital markets. FIA EPTA members found broad support for the FCA’s proposals and found them to be mostly welcome enhancements to the current approach to post-trade transparency.
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FIA EPTA response to IOSCO Consultation Report CR04/22: Exchange Traded Funds – Good Practices for Consideration
FIA EPTA appreciates the opportunity to comment on IOSCO’s proposed good practices, which we generally welcome. FIA EPTA supports open, fair, transparent and competitive markets. These principles have informed our responses. For example, we believe it is critical to ensure funds’ AP selection processes remain fair and open to new entrants, as this ultimately benefits end-investors and market resilience.
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FIA EPTA response to the ESMA Consultation Paper on ESMA’s Opinion on the trading venue perimeter
FIA EPTA appreciates the opportunity to provide feedback to the European Securities and Markets Authority (ESMA) on the consultation on ESMA’s Opinion on the trading venue perimeter. FIA EPTA considers that ESMA’s approach to defining multilateral systems is overly broad and risks creating further confusion and inconsistencies in the application of MiFID II across the Union.
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FIA EPTA response on the BaFin Consultation on a planned General Administrative Act regarding Futures with additional payment obligations
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.
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FIA EPTA response consultation on the review of the central clearing framework in the EU
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.
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FIA EPTA response to the IOSCO Consultation Paper on Operational resilience of trading venues and market intermediaries during the COVID-19 pandemic
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.
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