Publications & Filings
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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 ESMA consultation on clearing fees and associated costs disclosure requirements
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.
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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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FIA submits request for clarification on EMIR 3.0 active account representativeness
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.
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FIA responds to ASX dynamic default fund consultation
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.
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FIA responds to FCA consultation on ancillary activities exemption
FIA supports replacing the market share test with an annual threshold test, but raises concerns about the suggested inclusion of trading venue activity. Doing so would add complexity, increase compliance costs, and reduce UK competitiveness relative to the EU and the US, where only non-venue derivatives are counted.
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