EFAMA has published its response to the UK FCA’s consultation paper (CP23/28) on updating its regime for Money Market Funds (MMFs). While fundamentally agreeing on the need to definitely remove the existing link between liquidity breaches and the potential activation of LMTs for stable NAV MMFs, we express significant reservations with the proposed enhancements to the existing liquidity ratios across all types of MMF structures. 

The UK regulator (FCA) has taken a pragmatic approach in developing its Overseas Fund Regime (OFR) specifying the process that European retail funds would have to follow to gain, and keep, access to the UK market. This regime, which will replace the Temporary Marketing Permission Regime (TMPR), offers a streamlined access to the UK market in comparison to the current and time-consuming recognition process which is open to all overseas funds (...)

The proposal by the European Commission to amend the Benchmarks Regulation represents an overall welcome development in this field, seeking to introduce greater proportionality in the regulation of index providers. While we support the spirit of the proposal, EFAMA advocates retaining certain minimum safeguards applicable to non-significant benchmarks for the protection of users and end investors.