FIA has published a paper outlining its views on how to support the progress of the European Union’s Capital Markets Union. The paper – Capital Markets Union at a Critical Juncture – sets out the role that derivatives play in effective capital markets. Specifically, FIA believes that centrally cleared derivatives are a key ingredient to building a strong CMU.
CONTINUE READINGEnergy markets have been subject to a series of shocks in the past few years, all of which have had a significant impact on prices of the derivatives traded on these products and as a consequence the margin requirements demanded from traders in the derivatives market.
CONTINUE READINGIn a letter filed with the Securities and Exchange Commission (SEC), the FIA Principal Traders Group (FIA PTG) responded to the Option Clearing Corporation (OCC) Proposal to establish a margin add-on charge to help mitigate the risks of zero-days-to-expiration (0TED) options.
CONTINUE READINGFIA EPTA welcomes the opportunity to respond to the EBA’s Discussion Paper on the Call for Advice on the Investment Firms Prudential Framework (DP). We note that this DP offers limited discussion points and suggests many proposals for changes with no associated questions. We also believe that these proposed changes intend to borrow further requirements and methodologies existing in CRR.
CONTINUE READINGIt is very important to recognise that prudential regulations have a key impact on the functioning of capital markets and policies should be proportionate and should achieve the right balance between mitigating prudential risk while promoting competition, competitiveness and the overall goal of improving the EU’s capital markets within the CMU.
CONTINUE READINGAs high-volume consumers of a variety of wholesale market data products, our members support regulatory efforts to bring more transparency to market data pricing and fairness to commercial practices. We welcome ESMA’s efforts to strengthen this framework through the proposals set out in the consultation paper and draft RTS. In order for these proposals to be effective in practice, supervisory convergence is essential particularly regarding scrutiny of data providers’ approach to implementing the fees, costs and margin provisions. Adequate supervision and enforcement of this RTS across all NCAs is also essential for it to be effective.
CONTINUE READINGFIA EPTA members believe a comprehensive consolidated tape is essential for improving the international competitiveness and accessibility of EU markets to international investors many of whom currently find EU markets too complex and opaque. A comprehensive low cost, real-time, pre-trade CT will support transparency, ameliorate fragmentation and will support liquidity and investor confidence, strengthening EU financial markets.
CONTINUE READINGFIA EPTA members are generally supportive of ESMA’s proposed changes to the RTS on synchronisation of business clocks. In relation to the proposed extension of the clock synchronisation requirements to new entities, in general, we agree with the proposed accuracy levels for APAs, SIs, DPEs and CTPs subject to one exception: we believe that the accuracy levels for SIs with a gateway-to-gateway latency less than one millisecond should be the same as that for trading venues and their participants with the same gateway-to-gateway latency.
CONTINUE READINGOur members support the objectives of the MiFIR Review to enhance pre and post trade transparency in non-equity instruments. Our members believe that fully operative and genuine post-trade transparency provides significant advantages for both retail and institutional investors such as better, more reliable pricing, lower transaction costs and better liquidity across all trade sizes, including the largest sized block trades.
CONTINUE READINGFIA responded to the EBA-ESMA discussion paper on the European Commission call for advice on the investment firms' prudential framework, noting the importance of ensuring EU IFR/D is fit for purpose and that the application of prudential rules to commodity firms would be inappropriate, unduly complex, disproportionate and limit market entry for many small-size market participants.
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