We welcome this opportunity to comment on a review of the TV perimeter, and support ESMA’s objective of clarifying when systems and facilities qualify as multilateral.
Investment managers, acting on behalf of their retail and institutional clients, are among the largest investors in financial markets. They represent a key component of the market’s “buy-side” segment.
In representing the interests of its members on wholesale capital market issues, EFAMA advocates for fair, deep, liquid, and transparent capital markets, supported by properly regulated and supervised market infrastructure.
We welcome this opportunity to comment on a review of the TV perimeter, and support ESMA’s objective of clarifying when systems and facilities qualify as multilateral.
EFAMA welcomes the opportunity to respond to the EC’s targeted consultation on the EU’s central clearing framework. We are pleased to find in this consultation document a fair reflection of the complexity of the CCP ecosystem and consistency with the issues raised in previous dialogues held with the European Commission. In that same spirit, we hope in our response to provide feedback that resonates with the EC’s broader policy objectives while minimizing systemic risk and undue harm to our industry.
The European Fund and Asset Management Association (EFAMA) welcomes the opportunity to respond to this important review of RTS 153/2013 and accompanying guidelines, in light of the procyclicality witnessed during the peak volatility of the Covid crisis. European CCPs already have standard anti-procyclicality tools in their rulebooks and this did lead to less volatile moves in margin in Europe versus other jurisdictions.
EFAMA welcomes the recent proposal by European exchanges to build a consolidated tape. This affirms the buy-side’s long standing view that a European consolidated tape is key to completing the objectives of the Capital Markets Union and ensuring that European capital markets remain globally competitive. We have identified important use-cases for institutional and retail investors alike, not least in the ability to receive best execution on trades.
3 June 2022 - EFAMA, ICSA and MFA (the Associations) have read IOSCO’s Feedback Statement on “Market Data in the Secondary Equity Market” following the IOSCO consultation in 2021, and warmly welcome its conclusions.
The Associations would like to draw attention towards the executive summary in particular, where a number of valuable insights and recommendations are presented. For example, we fully support the statement below, though we would suggest an important addition:
A Cross-Industry Consensus on the EU Equity Consolidated Tape Proposal - Statement of Principles
EFAMA, AFME, BVI and Cboe agreed on a set of 11 Principles.
The provision of an appropriately constructed EU Equities Consolidated Tape (“CT”) will democratise access to equities (as proposed by the EU Commission) for all investors, regardless of resources or sophistication, with a comprehensive and standardised view of EU equities prices.
The London Interbank Offered Rate, also known as LIBOR®, is a widely-used index for short-term interest rates that is commonly found in
A key purpose of the financial system is to allocate capital and risk in a manner that supports sustainable economic development and growth, including through the provision of financing, investment and hedging products. Financial benchmarks/indices are fundamental to the functioning of financial markets and are widely used in both retail and wholesale markets. In particular, benchmarks are a valuable tool helping market participants to set prices, measure performances, or work out amounts payable under financial contracts or instruments.