EFAMA welcomes this opportunity to comment on the review of the provisions within the Short Selling Regulation. We have limited our responses to those questions of most relevance to our membership.
Capital markets
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.
ESMA Consultation on the review of certain aspects of the short selling regulation
UK clearing house equivalence - request from nine trade associations
Nine associations (AFME, AIMA, EAPB, EBF, EFAMA, FIA, ICI, ISDA, SIFMA AMG) welcome the Commission's decision to grant a time-limited equivalence decision in respect of UK CCPs. However, when this time-limited equivalence decision expires on 30 June 2022, there remains a significant risk of disruption to clearing for EU firms and to their access to global markets.
Joint association letter on the CSDR Settlement Discipline implementation timeline
On 14 July 2021, sixteen trade associations, representing buy-side, sell-side and market infrastructures, wrote to ESMA and the European Commission regarding the timeline for implementation of the mandatory buy-in rules as part of the CSDR Settlement Discipline Regime.
The Joint Associations welcome the Report from the Commission on the CSDR Review published in July 2021 and fully support the Commission’s intention to consider amendments to the mandatory buy-in regime, subject to an impact assessment.
Buy-side use-cases for a real-time consolidated tape
A real-time consolidated tape, provided it is made available at a reasonable cost, will bring many benefits to European capital markets. A complete and consistent view of market-wide prices and trading volumes is necessary for any market, though this is especially true for the EU where trading is fragmented across a large number of trading venues. A real-time consolidated tape should cover equities and bonds, delivering data in ‘as close to real-time as technically possible’ after receipt of the data from the different trade venues.
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Statement on the release of the Oliver Wyman study ‘Caught on Tape’
“Oliver Wyman’s study ‘Caught on Tape’ provides a perplexing take on Consolidated Tape for Europe. Sure enough, it starts with accurate observations: the high number of trading venues in Europe, the resultant fragmented liquidity, unseen liquidity due to the lack of a consolidated tape, and the fact that leading markets like the US and Canada today benefit from a real time consolidated tape.
Global Memo: Benchmark Data Costs
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.
3 questions to Agathi Pafili on CSDR
Q #1 What is the CSDR’s Settlement Discipline Regime (SDR) and what does it seek to achieve?
Asset Management in Europe - An Overview of the Asset Management Industry - November 2020
The report aims to provide a unique and comprehensive set of facts and figures on the state of the industry at the end of 2018 but also to highlight the fundamental role of asset managers in the financial system and wider economy.