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Review of the appropriate prudential treatment for investment firms

Banking and financial services

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Public consultation

ID: 1307

Lobbying Activity

29 responses

Consultation response

Fédération bancaire française, 14 Feb 2018

The French Banking Federation (FBF) represents the interests of the banking industry in France. Its membership is composed of all credit institutions authorized as banks and doing business in France, i.e. more than 390 commercial, cooperative and mutual banks. FBF member banks have more than 38,000…

Consultation response

Fédération bancaire française, 14 Feb 2018

The French Banking Federation (FBF) represents the interests of the banking industry in France. Its membership is composed of all credit institutions authorized as banks and doing business in France, i.e. more than 390 commercial, cooperative and mutual banks. FBF member banks have more than 38,000…

Consultation response

The Danish Chamber of Commerce, 12 Feb 2018

The Danish Chamber of Commerce feedback on the proposal for a Revised Framework for Investment Firms The Danish Chamber of Commerce welcomes the Commission’s proposal for a revised framework on the prudential requirements for Investment Firms. Investment firms play a vital role in facilitating…

Consultation response

Invest Europe, 19 Apr 2017

Invest Europe supports the principle of establishing a prudential regime better tailored to investment firms and welcomes initiatives to ensure the regime does not give rise to unnecessary complexity and disproportionate costs and requirements for firms which are small and do not conduct “bank-like…

Consultation response

BlackRock, 19 Apr 2017

The current CRD/CRR regime which is primarily designed to mitigate the risks to shareholders and taxpayers of inappropriate risk taking within banking entities, neither sufficiently takes into account the different risk profiles of other investment firms nor reflects the many other risk mitigants…

Consultation response

Deutsche Börse AG, 8 Mar 2018

Deutsche Börse Group (DBG) welcomes the opportunity to provide Feedback on the EU Commission's proposals for a new prudential Regime for Investment Firms. We generally Support the objectives of the draft proposals; from our point of view it is important that capital requirements are calibrated in a…

Consultation response

London Stock Exchange Group, 8 Mar 2018

• LSEG welcomes the European Commission’s (the Commission’s) proposal for a Prudential Framework for Investment Firms. We recommend that the Regulation and Directive should be more proportionate than envisaged by the EBA in its application to principal traders acting as market liquidity providers,…

Consultation response

Federation of European Securities Exchanges, 8 Mar 2018

The Federation of European Securities Exchanges (FESE) welcomes the underlying objective followed in the Commission’s legislative proposals on designing a new prudential regime for investment firms, i.e. to categorise investment firms into three classes based on the risks they pose and to attach…

Consultation response

Federation of European Securities Exchanges, 8 Mar 2018

The Federation of European Securities Exchanges (FESE) welcomes the underlying objective followed in the Commission’s legislative proposals on designing a new prudential regime for investment firms, i.e. to categorise investment firms into three classes based on the risks they pose and to attach…

Consultation response

AMUNDI AM, 8 Mar 2018

Amundi shares the intent of the European Commission (EC) to take into account the variety of activities and business models of Investment Firms (IF) and the structural differences with Credit Institutions. We are sorry, though, that the first dividing line between firms that operate on their…

Consultation response

AMUNDI AM, 8 Mar 2018

Amundi shares the intent of the European Commission (EC) to take into account the variety of activities and business models of Investment Firms (IF) and the structural differences with Credit Institutions. We are sorry, though, that the first dividing line between firms that operate on their…

Consultation response

BVI Bundesverband Investment und Asset Management e.V., 8 Mar 2018

BVI supports the Commission’s proposal to introduce a separate new framework in the form of a European Directive (IFD) and a directly applicable Regulation (IFR) on the prudential requirements of non-systemic investment firms outside the banking sector. However, the new framework has a significant…

Consultation response

BVI Bundesverband Investment und Asset Management e.V., 8 Mar 2018

BVI supports the Commission’s proposal to introduce a separate new framework in the form of a European Directive (IFD) and a directly applicable Regulation (IFR) on the prudential requirements of non-systemic investment firms outside the banking sector. However, the new framework has a significant…

Consultation response

BVI Bundesverband Investment und Asset Management e.V., 19 Apr 2017

We refer to our attached file.

Consultation response

European Fund and Asset Management Association, 8 Mar 2018

EFAMA strongly supports the proposal’s underlying objective to achieve a more proportionate and self-standing regime for a multitude of non-bank investment firms compared to the existing one under CRD/CRR. Among these firms are MiFID-licensed asset management companies offering individual portfolio…

Consultation response

Vanguard Asset Management Limited, 19 Apr 2017

Vanguard Asset Management, Limited (VAM) welcomes the opportunity to provide feedback on the review of the appropriate prudential treatment for investment firms (the Review"). Further details of how VAM, and the broader Vanguard group, operates, is set out in the position statement provided in…

Consultation response

The Investment Association, 8 Mar 2018

The Investment Association (IA) is the trade body for the UK investment management industry representing £6.9 trillion of assets managed by more than 230 members. Our member firms include managers of a wide range of asset classes for a wide range of clients, including institutional funds,…

Consultation response

FIA European Principal Traders Association, part of FIA, Inc., 22 Feb 2018

FIA EPTA welcomes the European Commission’s legislative proposals for a Directive and a Regulation on the prudential supervision, and the prudential requirements, of investment firms (the Investment Firm Review (IFR) Directive and Regulation or IFRD / IFRR). We enthusiastically support the…

Consultation response

FIA European Principal Traders Association, part of FIA, Inc., 22 Feb 2018

FIA EPTA welcomes the European Commission’s legislative proposals for a Directive and a Regulation on the prudential supervision, and the prudential requirements, of investment firms (the Investment Firm Review (IFR) Directive and Regulation or IFRD / IFRR). We enthusiastically support the…

Consultation response

FIA European Principal Traders Association, part of FIA, Inc., 19 Apr 2017

FIA EPTA – Review of the appropriate prudential treatment for investment firms FIA EPTA members welcome the opportunity to provide comments on this initiative at this early stage. We have continuously been engaged with the Commission, EBA and national competent authorities throughout the process…

Consultation response

Stichting European Federation of Energy Traders (We operate under the name Energy Traders Europe), 8 Mar 2018

Please see the attached file.

Consultation response

Stichting European Federation of Energy Traders (We operate under the name Energy Traders Europe), 8 Mar 2018

Please see the attached file.

BNY Mellon warns of drafting errors in investment rules

The Bank of New York Mellon, 8 Mar 2018

The firm requests that unclear definitions regarding credit institutions be redrafted to ensure legal certainty. They also suggest reviewing the term "institution" across EU law to protect existing business activities.
This ensures the firm can continue providing services without legal or operational disruptions.
Investment firms and their clients lose access to services due to technical drafting errors.

Consultation response

Futures Industry Association, Inc., 8 Mar 2018

FIA is the leading global trade organization for the futures, options and centrally cleared derivatives markets, with offices in London, Singapore and Washington, D.C. FIA’s membership includes clearing firms, exchanges, clearinghouses, trading firms and commodities specialists from more than 48…

Consultation response

Association Française des Marchés Financiers, 26 Feb 2018

Association française des marchés financiers (AMAFI) is the trade organisation working at national, European and international levels to represent financial market participants in France. It acts on behalf of credit institutions, investment firms and trading and post-trade infrastructures,…

Consultation response

ABN AMRO Clearing Bank N.V., 27 Feb 2018

ABN AMRO Clearing Bank N.V. (AACB), has taken note of the European Commission (EC) proposal for a regulation on the prudential requirements of investment firms. AACB is the global top-3 provider of clearing and financing services for listed derivatives, cash securities, warrants, commodities…

Consultation response

Legal & General Group Plc, 7 Mar 2018

We welcome the opportunity to respond to the European Commission’s draft legislative proposal, and are supportive of the Commission’s aim of creating a tailored prudential regime for investment firms. Overall, we see the package, subject to our comments in the attached, as being a positive step…

Consultation response

BIPAR - European Federation of Insurance Intermediaries, 8 Mar 2018

Please find attached BIPAR feedback to the Review of the appropriate prudential treatment for investment firms.

Consultation response

BIPAR - European Federation of Insurance Intermediaries, 19 Apr 2017

BIPAR welcomes the opportunity provided by the European Commission to comment on its Inception Impact Assessment on the review of the appropriate prudential treatment for investment firms. BIPAR represents 53 national associations of insurance and financial intermediaries. Many of the financial…