Publications & Filings
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FIA comments on draft amendments of the PRC Enterprise Bankruptcy Law
FIA recommends involving the China Securities Regulatory Commission alongside other authorities when determining the scope of qualified financial transactions, and ensuring equal legal protection for similar products regardless of where they are traded, cleared or settled. FIA also proposes adding a new article providing clear recognition and protection for financial market infrastructure operators.
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FIA responds to request for comment from TMX on ongoing information requirements for approved participants
In responding to proposed rule changes from TMX, FIA expresses support for the larger project underway to revise TMX's Approved Persons framework and voices concerns about the burden associated with the most recent proposed rule changes.
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FIA responds to EBA consultation on non-ICT third-party risks
FIA has responded to the European Banking Authority’s consultation on third party risk management for non-ICT services. In the response, FIA highlights issues for consideration by the EBA for the guidelines to more proportionately enhance third party oversight in the EU financial sector landscape.
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FIA comments on ICE's US Treasury clearing proposal
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.
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FIA responds to ECB consultation on extension of T2 operating hours
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.
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FIA asks CFTC to sunset swaps large trader reporting rules
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.
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FIA responds to ESMA on simplifying regulatory reporting requirements in the EU
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.
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FIA responds to ESMA consultation on margin transparency requirements
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.
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FIA responds to SEBI closing auction session proposal
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.
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FIA responds to SEBI consultation on restructuring of indices with derivatives contracts
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.
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