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FIA European Principal Traders Association, part of FIA, Inc.

FIA EPTA

FIA EPTA represents independent market makers and liquidity providers in European financial markets.

Lobbying Activity

Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

7 Jan 2026 · Discussion on ESMA’s Final Report on transparency for exchange-traded derivatives

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and

5 Dec 2025 · Reporting under Article 7d of EMIR (Regulation (EU) No 648/2012)

Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

7 Oct 2025 · Commodity derivatives

Meeting with Dirk Gotink (Member of the European Parliament)

4 Jun 2025 · SIU

Meeting with Auke Zijlstra (Member of the European Parliament)

3 Jun 2025 · Clearing

Meeting with Jonás Fernández (Member of the European Parliament)

3 Jun 2025 · Saving and Investment Union

Meeting with Cristina Dias (Cabinet of Commissioner Maria Luís Albuquerque), Nuno Vaz (Cabinet of Commissioner Maria Luís Albuquerque)

10 Apr 2025 · Short meeting at the margins of the Eurofi High-Level Seminar in Warsaw

Response to Savings and Investments Union

7 Mar 2025

FIA EPTA strongly supports the European Commissions objectives for the Savings and Investment Union as a critical foundation for a safe, prosperous and green future for EU citizens. The need for mobilising private capital is crystal clear: securing Europes defence capacity, digitising the economy, and transitioning to a climate-neutral continent will all require significant capital investment. Vibrant, resilient and competitive capital markets will be essential for the EU to secure the necessary growth and economic security for its citizens. In this regard, we fully agree with the Commissions key message in its recent Communication on A Competitiveness Compass for the EU, that The EU must integrate and have deeper and more liquid capital markets as a necessary step to mobilise private sector resources and direct them towards future oriented growth sectors. A critical component for achieving these objectives will be for the Commissions SIU action plan to take into account the critical role of liquidity provision by Principal Trading Firms for the success of EU capital markets. It is from this standpoint that FIA EPTA representing the leading firms providing liquidity to European end-investors and markets suggests three main areas of reform to invigorate EU capital markets: 1. Strengthening the single market for capital by advancing supervisory convergence and making targeted progress toward a more integrated and interoperable market structure supported by more efficient supervisory arrangements, including targeted and realistic steps toward more centralised supervision; 2. Enhancing the attractiveness and global competitiveness of EU markets by setting clear competitiveness objectives, fostering greater competition, streamlining regulatory processes, and simplifying regulatory regimes; 3. Unlocking additional liquidity by implementing targeted regulatory reforms to ensure proportionate prudential requirements for investment firms and apply robust transparency regimes to support competition and healthy price formation. Additionally, more incoming global investment should be encouraged by strengthening regulatory coordination and cooperation across the entire European trading region. Currently, European markets face a significant liquidity shortfall compared to other regions. Notably, the EU is underperforming relative to the US and is increasingly falling behind other global markets. As the industry association representing Europes independent market makers who provide liquidity to European end-investors and markets, FIA EPTA is strongly committed to reversing this trend. Principal Trading Firms play a crucial role in strong and resilient capital markets by providing liquidity, facilitating price discovery and enabling risk management for investors. As the most urgent action to unlock additional liquidity provision in EU capital markets, targeted improvements are needed to the prudential rules for investment firms (IFR/IFD). Currently, the EU uniquely imposes comprehensive, bank-like prudential requirements on investment firms, putting itself at a competitive disadvantage compared to other major global capital markets centers. IFR/IFD unduly limit the ability of Principal Trading Firms to provide optimal liquidity, not least during periods of market volatility. Consequently, the IFR/IFD framework impedes the development of EU capital markets. For this reason, FIA EPTA strongly advocates for a targeted, but meaningful, legislative Review of IFR/IFD as a key building block for the Commissions SIU action plan. We provide our further recommendations for competitive EU capital markets underpinned by strong liquidity provision in the attachment to this submission.
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Meeting with Maria Raffaella Assetta (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Insurance Europe and

4 Mar 2025 · EU financial services industry associations debrief on EU-UK Financial Regulatory Forum

Meeting with Andrea Wechsler (Member of the European Parliament) and Verein Deutscher Zementwerke e.V. and Raízen SA

25 Feb 2025 · EU Energy and industry policy

Meeting with Almoro Rubin De Cervin (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

23 Jan 2025 · Capital Requirements Regulation, Capital Requirements Directive, Investment Firms Directive

Meeting with Valvanera Ulargui Aparicio (Cabinet of Executive Vice-President Teresa Ribera Rodríguez) and Insurance Europe and

16 Dec 2024 · Exchange with the Independent Service Providers (ISPs) on the upcoming Commission Initiatives that will support the whole sector competitiveness, including the Competitiveness Compass, the Clean Industry Deal and the Automotive Industry Plan

Meeting with Jonás Fernández (Member of the European Parliament)

3 Dec 2024 · Capital Markets Union

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Shadow rapporteur)

15 Nov 2024 · EMIR

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament) and Euronext

13 Sept 2024 · Capital Markets Union

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and FTI Consulting Belgium

13 Jun 2024 · Capital Markets Union upcoming trends in market infrastructure

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Rapporteur) and Deutsche Bank AG

23 Feb 2024 · Retail investment Strategy

Meeting with Danuta Maria Hübner (Member of the European Parliament, Rapporteur) and London Stock Exchange Group

13 Oct 2023 · European Market Infrastructure Regulation (EMIR) Review (Meeting with APA)

Meeting with Danuta Maria Hübner (Member of the European Parliament, Rapporteur)

23 May 2023 · EMIR review

Meeting with Aurore Lalucq (Member of the European Parliament, Shadow rapporteur)

30 Mar 2023 · EMIR

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

20 Sept 2022 · Cleared Derivatives

Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness) and Federation of European Securities Exchanges and

11 Jan 2022 · Investment Firms prudential framework

Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean)

17 Nov 2021 · Meeting to discuss road safety

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and FTI Consulting Belgium

11 Nov 2021 · Investment Firms Directive and Regulation

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and JPMorgan Chase & Co. and

5 Oct 2021 · MIFID review, CCP equivalence

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and Citadel LLC

9 Sept 2021 · MiFID

Response to Delegated Act on the adjustment of the threshold for the notification of significant net short positions in shares

12 Aug 2021

Consultation response - FIA EPTA European Commission consultation on permanently lowering the relevant threshold for the notification of significant net short positions in shares • FIA EPTA welcomes the opportunity to respond to the European Commission’s consultation on permanently lowering the relevant threshold for the notification of significant net short positions in shares. • Short selling plays an important role in ensuring the proper functioning of financial markets in terms of liquidity and efficiency of price formation. It enables investors to manage risk and market-makers to facilitate risk transfer for others by hedging their positions through buying and selling shares. It is thus important that transparency requirements are well-calibrated, easy to implement and do not unduly detract from the benefits that short selling provides to the EU capital markets. • FIA EPTA stands in favour of enhancing transparency of markets and takes note of the reasons why ESMA has used its extraordinary powers to temporarily lower the threshold for notification of significant net short positions in shares during Covid-19 economic turmoil. However, FIA EPTA believes that before permanently lowering the relevant threshold, the European Commission should consider the added value of the resulting increase of number of disclosures and associated costs and acknowledge the need for a common short-selling disclosure system to avoid unnecessary burden for market participants and National Competent Authorities. We would also like to understand what goal is ultimately reached by lowering the threshold to a non-substantial percentage. • Furthermore, FIA EPTA regrets the absence of a full cost-benefit analysis, based on a normal-market situation. Such an analysis would have underlined the fragmentation issue of the current short-selling disclosure framework and brought further clarity on the added value of lowering on a permanent basis the relevant threshold. We, therefore, call on an efficiency analysis first of the current threshold before gathering more information as per the result of the proposed change. PLEASE FIND FURTHER BACKGROUND IN THE PDF ATTACHED.
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Response to An act specifying when commercial terms of central clearing are fair, reasonable, non-discriminatory and transparent

7 Apr 2021

Please find comments by the FIA European Principal Traders Association (FIA EPTA) in the attached document.
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Response to Capital markets – research on small and mid-sized companies and fixed income (updated rules in light of the COVID-19 pandemic)

11 Sept 2020

FIA EPTA welcomes the opportunity to provide feedback on the proposed MiFID II Quick-fix rules in relation to research on companies seeking alternative financing. Overall, we believe that the unbundling rules laid out in MiFID II removed an important source for conflicts of interest and has reinforced the independence of research. We note that the market has fully implemented and adapted to research unbundling with clients now accustomed to receiving disaggregated cost information that differentiates between costs attributable to research from those related to execution. Prior to the introduction of unbundling rules, pricing between research and execution services was often unclear and, in some cases, inflated. MiFID II has resolved this cross-subsidizing and increased pricing transparency. Research and value-added services are now priced independently so each service is rewarded and priced based on quality and cost. We consider that this helps achieve a more level playing field for order execution. Unbundling enables end-investors to have a better view of execution cost and to assess added value of high-touch versus low-touch execution for them. Following the implementation of the MiFID II unbundling rules, end-investors have increasingly opted for low-touch execution via the public market, i.e., on-exchange -- including via RFQ platforms -- or through an SI where they can trade directly with liquidity providers in a more transparent, efficient and low cost environment. This has benefited institutional and ultimate retail investors alike. We are concerned that re-bundling would lead to a roll-back of these benefits, which would be at odds with MiFID II’s objective to incentivise pre-trade transparent price formation in a regulated execution environment. With this in mind, we have concerns regarding the proposal to re-bundle research and execution costs. In particular, allowing for re-bundling risks undermining other core MiFID II objectives, namely the obligation to execute transactions on the terms most favourable to the client or best execution. Re-bundling in the case of transactions for SME shares and fixed income products would prevent clients from measuring best execution and the quality of the service they receive in transactions involving these instruments. FIA EPTA members reiterate, therefore, that offering research in a bundled manner jointly with execution pricing constitutes an undue inducement that should continue to be banned under MiFID. An additional concern is the creation of divergent requirements applicable to equity and fixed income products which appears arbitrary. We note there is no apparent justification for dis-applying unbundling requirements for fixed income products. Accordingly, we favour retaining consistent requirements for equity and fixed income markets that maintains the high level of transparency that investors have grown accustomed to since the application of MiFID II. It is our view that European capital markets would face an undue risk by disapplying the unbundling requirements and could see the industry going in the wrong direction towards less transparency, additional costs and increased operational complexity. This potential step back puts global firms at odds with requirements in other regions of the world such as the UK (where the positive contributions of unbundling to market quality are clearly recognised) or the US where firms are moving towards more unbundled agreements on the back of the positive effects the unbundling rules have had in Europe. Finally, we also note also that extensive recent analysis by ESMA did not find material evidence of harmful effects stemming from the MiFID II unbundling rules. ESMA found that any impacts on quality and volume of research were dwarfed by longstanding trends that are unrelated to the implantation of MiFID II. In light of these findings and our comments above, we would strongly urge the Commission to reconsider its proposal.
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Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis) and FTI Consulting Belgium

13 Feb 2019 · Investment Firm Review (IFR)

Response to Review of the appropriate prudential treatment for investment firms

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 Commission’s commitment to crafting a more simple prudential regime for non-systemic investment firms with more proportionate own funds requirements. However, we note that in spite of the concerns expressed by FIA EPTA as well as other stakeholders regarding some of the recommendations in the European Banking Authority’s (EBA) September 2017 technical advice, these recommendations have been reflected in the IFR proposals. We believe that, if adopted in law, these elements of the proposals may undermine the Capital Markets Union (CMU) objectives of a simpler, more proportionate prudential regime for non-systemic investment firms and will diminish the quality and competitiveness of European capital markets. We also believe that some recommendations may need to be adjusted to fully meet key objectives of, and prevent conflict with, Directive 2014/65/EU on markets in financial instruments (MiFID II) and Regulation (EU) No 600/2014 on markets in financial instruments (MiFIR). In particular, we would like to draw attention to: (a) Classification: the de-facto permissions-based classification of non-systemic investment firms, including principal trading firms (PTFs), is arbitrary and may create barriers to entry to the detriment of the diversity and competitiveness of European capital markets; (b) Risk to Market (RtM) K-factors: the proposed formula for the calculation of RtM is suboptimal. The requirement to use the higher of the two K-factors would force market participants to calculate at least two different methods for setting own-funds requirements, thus raising compliance costs. Moreover, the “higher of” approach would effectively subordinate the K-factor on “clearing member guarantee” (K-CMG) to the K-factor on “net position risk” (K-NPR), thus undermining the proven accuracy and stability of clearing margin collateral models; (c) Calculation of K-NPR: the consequences of the full application of the Basel Committee on Banking Supervision’s (BCBS) revised market risk standard (also known as the “Fundamental Review of the Trading Book” or FRTB) to non-systemic investment firms warrants close scrutiny. We note that the efficacy and impact of FRTB on systemic firms, those for whom it was developed, has yet to be determined; (d) K-factor on “daily trading flow” (K-DTF): As a proxy for operational risk, K-DTF is not fit for purpose; its procyclical nature risks conflicting with the objectives of both MiFID II and the CMU.
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Response to Review of the appropriate prudential treatment for investment firms

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 Commission’s commitment to crafting a more simple prudential regime for non-systemic investment firms with more proportionate own funds requirements. However, we note that in spite of the concerns expressed by FIA EPTA as well as other stakeholders regarding some of the recommendations in the European Banking Authority’s (EBA) September 2017 technical advice, these recommendations have been reflected in the IFR proposals. We believe that, if adopted in law, these elements of the proposals may undermine the Capital Markets Union (CMU) objectives of a simpler, more proportionate prudential regime for non-systemic investment firms and will diminish the quality and competitiveness of European capital markets. We also believe that some recommendations may need to be adjusted to fully meet key objectives of, and prevent conflict with, Directive 2014/65/EU on markets in financial instruments (MiFID II) and Regulation (EU) No 600/2014 on markets in financial instruments (MiFIR). In particular, we would like to draw attention to: (a) Classification: the de-facto permissions-based classification of non-systemic investment firms, including principal trading firms (PTFs), is arbitrary and may create barriers to entry to the detriment of the diversity and competitiveness of European capital markets; (b) Risk to Market (RtM) K-factors: the proposed formula for the calculation of RtM is suboptimal. The requirement to use the higher of the two K-factors would force market participants to calculate at least two different methods for setting own-funds requirements, thus raising compliance costs. Moreover, the “higher of” approach would effectively subordinate the K-factor on “clearing member guarantee” (K-CMG) to the K-factor on “net position risk” (K-NPR), thus undermining the proven accuracy and stability of clearing margin collateral models; (c) Calculation of K-NPR: the consequences of the full application of the Basel Committee on Banking Supervision’s (BCBS) revised market risk standard (also known as the “Fundamental Review of the Trading Book” or FRTB) to non-systemic investment firms warrants close scrutiny. We note that the efficacy and impact of FRTB on systemic firms, those for whom it was developed, has yet to be determined; (d) K-factor on “daily trading flow” (K-DTF): As a proxy for operational risk, K-DTF is not fit for purpose; its procyclical nature risks conflicting with the objectives of both MiFID II and the CMU.
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Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

19 Dec 2017 · Revised Framework for Investment Firms

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

24 Nov 2017 · Capital Markets Union

Response to Review of the appropriate prudential treatment for investment firms

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 so far and have sought to be a source of information for all matters pertaining to the activities of investment firms and principal trading firms (PTFs) in particular. We are supportive of this initiative and welcome a prudential regime tailored to the specific structures and market activities of investment firms. In this response we seek to emphasize some of the key issues, we hope, the Commission will take into account in its assessment. More details of our position on the new prudential regime for investment firms are included in the attached paper. Level playing field: We note the Commission’s aim of ensuring a level playing field between investment firms and credit institutions. While we agree that the new regime should avoid unnecessary burdens and regulatory disparities, we do not agree with the assertion that investment firms and credit institutions compete in providing investment services. FIA EPTA members do not hold client moneys or assets and do not generally provide brokerage, investment advice, portfolio management or underwriting. We understand the need to provide a level playing field for firms carrying out the same activity but this should not result in the application of inapt requirements that are not tailored to the specific characteristics of PTFs. Orderly wind-down: The preliminary assessment includes some consideration of the likely impacts of an investment firm failing and the economic losses incurred in insolvency proceedings. FIA EPTA members strongly believe the overarching objective of any prudential regime should be to ensure that investment firms have sufficient liquid funds to facilitate an orderly wind-down. FIA EPTA members do not generally have customers who would need to be protected through insolvency proceedings. The focus should instead be on ensuring minimal market impact in the unlikely event that a PTF fails. If a PTF was to fail its business would quickly be taken on by a competitor and its positions would generally be settled or sold off within two working days. Transactions undertaken by a PTF are generally cleared and subject to margin requirements preventing the spread of risk to the wholesale markets. FIA EPTA members are not systemic thus can be wound down rapidly and in an orderly manner with minimal impact on markets and market participants. Categorisation of investment firms: We broadly support the EBA’s recommendation to propose a three-fold classification of investment firms: Class 1) systemic and bank-like firms; Class 2) non-systemic and non-bank like firms; and Class 3) small, non-interconnected firms. We would encourage the Commission take these into account in performing its impact assessment. Many FIA EPTA members will be categorised as class 3 as their business is non-complex and relatively small. FIA EPTA members are not systemic. Our operations ensure that systemic concerns are limited and contained. We operate in transparent, competitive and strictly regulated markets and generally trade highly-liquid instruments. EBA Data Collection Exercise: We would like to take the opportunity to draw the Commission’s attention to the shortcomings of the EBA’s data collection exercise. In particular we are concerned that the voluntary nature of submissions in certain key jurisdictions and the lack of consideration for the volatility in daily trading rates will lead to a distorted picture of the market. This may in turn have a negative impact on the quality of the Impact Assessment (IA) that will need to be performed by the Commission in preparation for any legislative proposal.
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Meeting with Chantal Hughes (Cabinet of Commissioner Jonathan Hill)

14 Jun 2016 · CCP Recovery and Resolution