Publications & Filings
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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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ISDA, SIFMA and FIA comments on enhanced supplementary leverage ratio reforms
FIA, ISDA and SIFMA strongly support the proposed recalibration of the Enhanced Supplementary Leverage Ratio and urge the Federal Reserve, FDIC, and OCC to finalize the proposal as soon as possible, with an effective date no later than 1 January 2026.
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Joint trades call for recalibration of cryptoasset prudential standards and highlight DLT’s transformative role in capital markets
The Joint Trades recommend essential revisions of the Basel banking prudential treatment of cryptoassets and pausing implementation of SCO60 ahead of its January 2026 effective date to allow for a targeted consultation and redesign. The letter highlights the excessively conservative and overly punitive capital treatment of cryptoassets that is misaligned with actual risks, in addition to various inconsistencies with current market risk management practices.
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FIA responds to CFTC spot crypto listing initiative
FIA has responded to the US Commodity Futures Trading Commission’s spot crypto listing initiative, which invites stakeholders to work with the Commission “on providing regulatory clarity on how to list spot crypto asset contracts on CFTC-regulated designated contract markets” using the Commission’s “existing authority” under the Commodity Exchange Act.
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FIA and ISDA respond to Reserve Bank of Australia guidance for the clearing and settlement facility resolution regime
FIA and ISDA urge greater clarity in the RBA’s draft guidance on clearing and settlement facility resolution to enhance transparency, communication and market stability during interventions.
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FIA responds to Senate Banking RFI on market structure legislation
The Senate Banking Committee published its version of proposed legislation on market structure and digital assets and issued a request for information. FIA has responded with its views, including commentary on the role of the CFTC, the importance of market intermediaries, and other topics.
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FIA responds to TMX consultation on approved persons regime
FIA supports TMXs goals and objectives for a revised Approved Persons framework, particularly the simplification, modernization, and streamlining components. The comments it provides are intended to assist TMX in achieving these goals and objectives while also ensuring that the framework is practical and manageable for firms.
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