Prudential Regulation
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FIA EPTA response to the EBA Discussion Paper on the role of Environmental Risks in the Prudential Framework
FIA EPTA welcomes the opportunity to respond to the European Banking Authority (EBA) Discussion Paper on the role of Environmental Risks in the Prudential Framework. In 2019 FIA EPTA established a Sustainable Finance Committee for its member firms to explore how liquidity providers can contribute to the green transition. It is FIA EPTA’s view that sustainable finance offers a great promise in unlocking investment capital that is essential for fighting climate change and mitigating its impact for citizens.
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FIA EPTA response to the EBA CP on the Draft Regulatory Technical Standards on the specific liquidity measurement for investment firms
FIA EPTA welcomes the opportunity to respond to the EBA Consultation Paper on the Draft Regulatory Technical Standards on the specific liquidity measurement for investment firms under Article 42(6) of Directive (EU) 2019/2034. FIA EPTA would like to clarify that the concept of a liquidity mismatch between liquid assets and liquidity requirements, which is common for specific (asset management) business models like pension funds or investment funds, does not really apply to a market making model with a trading book and taking place in a CCP cleared environment or being governed by netting agreements.
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FIA EPTA response to the EBA Consultation Paper on the Draft Guidelines on common procedures and methodologies for the SREP under IFD
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.
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FIA EPTA Response to the EBA Consultation Paper on the Draft RTS on Pillar 2 add-ons for investment firms under Article 40(6) of Directive (EU) 2019/2034
FIA EPTA welcomes the opportunity to respond to the EBA Consultation Paper on the Draft Regulatory Technical Standards on Pillar 2 add-ons for investment firms under Article 40(6) of Directive (EU) 2019/2034. FIA EPTA is concerned about the fact that art. 4(2) of the draft Delegated Regulation effectively creates a floor with respect to the additional Pillar 2 requirements. This is the result of the fact that the additional own funds requirements as calculated in art. 4(1) are to express both (1) as an absolute amount, as well as (2) as the ratio of that amount to own funds requirements.
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FIA EPTA response to the Financial Conduct Authority (FCA) Consultation Paper on Regulatory fees and levies: policy proposals for 2022/23
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
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FIA EPTA response to the FCA Consultation Paper on a new UK prudential regime for MiFID investment firms (CP21/26***)
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.
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FIA EPTA Response to the Consultative Document “Prudential treatment of cryptoasset exposures by the Basel Committee
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.
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Response by FIA EPTA to the EBA consultation on Draft Regulatory Technical Standards on the reclassification of investment firms as credit institutions in accordance with Article 8a (6)(b) of Directive 2013/36/EU
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.
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FIA EPTA response to UK Government (BEIS) consultation on “Restoring trust in audit and corporate governance.”
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
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Response by FIA EPTA to the FCA’s second Consultation Paper on a new UK prudential regime for MiFID investment firms
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).
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