Publications & Filings
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FIA files comment letter opposing GSIB Surcharge Proposal
FIA filed a comment letter today with the Board of Governors of the Federal Reserve System expressing serious concerns with the significant increase in capital requirements for client derivatives clearing activities that the Board has proposed in its GSIB Surcharge Proposals. The changes would, on their own, increase the capital required to engage in client clearing activities by more than 58%.
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FIA joins industry call for adequate implementation time for REMIT II
FIA along with AFME, CMC Europe, EFET, Eurelectric, Eurogas, Europex, FESE, FIA EPTA, IOGP and ISDA has submitted a letter to European co-legislators urging them to delay the timing of the implementation of some of the obligations of the revised Regulation on Wholesale Energy Market Integrity and Transparency (REMIT II).
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FIA responds to Bank of England approach to discretionary payments by CCPs
FIA and ISDA have responded to the Bank of England's proposed statement of policy on discretionary payments by CCPs. The associations support the proposal but note they would welcome further guidance on how the BoE intends to consider the maintenance of public confidence in the UK financial system when using other supervisory and resolution powers.
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FIA responds to FSB consultation on CCP resolution financial resources and tools
FIA, IIF, and ISDA have responded to the Financial Stability Board's consultation report on financial resources and tools for CCP resolution. The response emphasises key concerns regarding the proposed approach, citing the need for increased transparency and predictability in resolution scenarios.
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FIA files comment letter in support of updating CFTC Rule 48.4
The FIA has filed a letter with the CFTC in support of a petition for rulemaking filed by Eurex requesting a technical update to CFTC Rule 48.4. Specifically, the FIA supported an expansion to the rule to permit U.S.-based IBs direct access to Foreign Boards of Trade.
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FIA submits comments to SGX on proposed changes to Futures Trading Rules
FIA has responded to the Singapore Exchange's consultation on proposed changes to its Futures Trading Rules and other rulebooks. While FIA generally supports the proposed changes, it also makes some recommendations and raises concerns about several proposals.
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FIA speaks on capital, exchange volatility controls before CFTC committee
FIA offered presentations before an advisory committee of the US Commodity Futures Trading Commission on 6 November, touching on best practices for exchange volatility controls and the potential impact of proposed capital reforms on OTC derivatives clearing.
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FIA responds to CFTC proposed rulemaking on Provisions Common to Registered Entities
FIA and ISDA have submitted a response to the CFTC proposed rulemaking on provisions to common registered entities. The proposal makes technical amendments to the CFTC rules governing how designated contract markets, derivatives clearing organizations, and swap execution facilities certify new rules and products, and the CFTC’s review and processing of such submissions.
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FIA voices continued opposition to SEC’s proposed custody rules for FCMs
FIA has filed additional comments opposing application of the US Securities and Exchange Commission’s proposed “safeguarding” rule to FCMs. The SEC recently re-opened the public comment period on the proposal, which would replace its existing custody rule for qualified custodians, including FCMs.
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Trade associations submit letter on Article 9 of REMIT
FIA and several other trade associations have sent a letter to trilogue parties regarding proposed changes to Art. 9 of the Regulation on Wholesale Energy Market Integrity and Transparency (REMIT) concerning the supervision of third country firms. The associations urge legislators to adopt the least burdensome of the pending proposals, which would have third-country firms designate a representative to respond to requests for information. This contrasts with having to establish an office or move principal trading operations to the EU, which would create considerable market access barriers.
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