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Publications & Filings

  • FIA responds to US FTC’s rule banning nearly all noncompete agreements

    FIA and FIA Principal Traders Group have filed an amicus brief along with several other financial services trade associations in a case involving the US Federal Trade Commission’s recently issued rule that bans nearly all noncompete agreements in the US. In their brief, the associations highlighted the practical challenges of the rule for the financial industry and warned that it would harm competition and endanger confidential information.

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  • FIA backs international effort to promote "effective practices" for variation margin

    FIA has responded to a discussion paper released by international standard setters that sets out eight "effective practices" for streamlining variation margin in centrally cleared markets. The discussion paper addresses the need for greater transparency and understanding of margin practices at central counterparties, particularly in light of recent episodes of market volatility triggered by the COVID crisis and Russia's invasion of Ukraine. 

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  • FIA asks CFTC to sunset large trader reporting for commodity swaps

    FIA, joined by ISDA, has responded to the CFTC’s notice of intent to renew the collection of large trader reporting (LTR) data for physical commodity swaps. The associations reiterate and build on requests they have made in recent years for the CFTC to sunset the LTR rules for swaps, which were envisioned as a temporary measure while the CFTC stood up its comprehensive swap reporting framework under Dodd-Frank.

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  • FIA responds to FCA proposal on publicising enforcement investigations

    FIA has responded to the UK Financial Conduct Authority’s public consultation on changes to its approach to enforcement investigations. The proposed changes include the FCA publicly announcing the opening of an investigation and disclosing the identity of the subject of the investigation where it considers this to be in the public interest. FIA is concerned that the proposed approach will be detrimental to the orderly functioning of UK capital markets, with limited value to public interest.

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  • FIA cautions CFTC on regulation of AI

    FIA has urged the CFTC to take a "technology-neutral" approach and focus on "outcomes and use cases" rather than the technology itself. FIA also urged the CFTC to consider the applicability of its existing rules and regulations before presupposing that new, AI-specific regulations are needed.

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  • FIA responds to CFTC Foreign Boards of Trade proposed rulemaking

    Under current rules, US-based commodity pool operators, commodity trading advisers, futures commission merchants and prop firms can directly access Foreign Boards of Trade. The pending rule would include US-based introducing brokers among the permissioned registrants. FIA’s letter supports the proposed expansion, noting that adding introducing brokers to the mix should provide more brokerage options for US customers and promote liquidity in foreign products.

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  • FIA responds to CFTC proposed rulemaking on FCM separate account margining

    FCMs are currently relying on no-action relief that allows them to separately margin accounts of the same beneficial owner. This rule marks the second attempt by the CFTC to codify that relief. FIA’s letter asks the CFTC to codify the relief as written without laying on additional highly prescriptive requirements that limit FCM discretion to risk manage accounts.

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  • FIA responds to JSCC consultation on initial margin and clearing fund calculation methods 

    FIA has submitted a response to the Japan Securities Clearing Corporation’s consultation, which proposes to introduce stress add-on initial margin charges and a partial revision of the clearing fund calculation method in its listed financial derivatives clearing service.

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  • FIA responds to FICC access and segregation proposals

    FIA has responded to the Fixed Income Clearing Corporation’s proposals to revise its customer clearing access models and to modify its margin segregation rules in order to implement the SEC’s new clearing mandate for U.S. Treasuries. FIA's response identifies conflicts between the proposed access structures and CFTC rules to which FCMs are subject.

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  • FIA calls on international regulators to continue progress on margin transparency

    FIA has filed a letter with international standard-setting bodies urging further progress on efforts to increase the resilience of global derivatives markets in times of stress. The letter was submitted in response to a consultation on initial margin requirements in centrally cleared derivatives markets that was issued by Basel Committee on Banking Supervision (BCBS), the Bank for International Settlements' Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO).

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