EFAMA welcomes the launch of this public consultation to evaluate and assess the effectiveness, efficiency and continued relevance of the DAC and its amendments (DAC2 to DAC6), as well as its coherence with other policy initiatives, priorities and the EU added value.

EFAMA agrees with the FSB that market participants should integrate the management of margin and collateral calls into their risk management, governance, and operational processes. 

The FCA’s recent report on the wholesale data market is an important and high-quality study which echoes many long-standing buy-side concerns. It finds evidence of unequal market power in terms of market concentration, highly profitable margins, opaque pricing practices, excessive charging, bundling practices and complex licensing agreements, all of which negatively impact data users. Much of this data is indispensable for users to stay in business and fulfil regulatory obligations.