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Securities Industry and Financial Markets Association

SIFMA

SIFMA is the leading trade association representing the broker-dealers, banks and asset managers who provide access to the global capital markets.

Lobbying Activity

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

9 Nov 2020 · The review of MiFID/R and the interplay with CMU,Taxonomy and IBOR transitions

Meeting with Valdis Dombrovskis (Vice-President) and

17 Oct 2019 · EU-US regulatory cooperation in financial services; upcoming work on MIFID II research; EC priorities on sustainable finance; regulatory fragmentation linked to the introduction of liquidity requirements on US branches of foreign bank organisations

Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis) and The Goldman Sachs Group, Inc. and K&L Gates GP - Brussels

13 May 2019 · CMU, MiFID, PRIIPs, Sustainable Finance

Meeting with Valdis Dombrovskis (Vice-President) and

11 Apr 2019 · Commission priorities in financial services for its next mandate, State of cross-border regulatory cooperation, Brexit, CFTC Cross-Border White Paper, BEAT

Meeting with Valdis Dombrovskis (Vice-President) and BlackRock and

30 Nov 2017 · Speech at EU-Asia Financial Services Dinner Reception on growth and investment in Europe; Fintech and sustainable finance

Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union)

21 Jun 2017 · Cross-Border regulatory coordination, Brexit, Cyber Security

Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis), Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis) and

21 Jun 2017 · first part of the regulatory review, cross-Border regulatory coordination, cyber security, Brexit and its external impacts

Meeting with Valdis Dombrovskis (Vice-President) and

20 Apr 2017 · CMU; Basel III; international cooperation on financial regulation; the Dodd Frank Act

Response to Extension of transitional period for CCPs

16 Nov 2016

Dear Sir/Madame: The Securities Industry and Financial Markets Association (“SIFMA”) welcomes the opportunity to provide feedback on the European Commission (“EC”) Draft Implementing Regulation that would extend the transitional periods related to own funds requirements for exposures to central counterparties (“CCPs”) set out in Regulations (EU) No 575/2013 and (EU) No 648/2012 of the European Parliament and of the Council. The Draft Regulation would extend the current transitional periods to June 15, 2017 from the current expiration of December 15, 2016. SIFMA and its members support this extension, as it will enable the continued thorough assessment of regimes still subject to equivalence determinations by the EC, while avoiding unnecessary market and liquidity disruptions. Under the European Market Infrastructure Regulation (“EMIR”), third country CCPs must be recognized by European Securities and Markets Authority (“ESMA”) to be deemed a Qualifying Central Counterparty (“QCCP”) under the EU Capital Requirements Regulation (“CRR”). As a pre-requisite, however, the EC must first deem the legal and supervisory frameworks of such third country CCPs as equivalent. Upon the expiration of current relief, European firms will incur onerous capital charges if they continue to access third country CCPs that have not yet been recognized by ESMA (i.e., non-QCCPs), effectively barring them from such activity. Thus, it remains critically important that the EC be provided with the time necessary to conduct equivalence assessments of the legal and supervisory frameworks of other third country CCPs, given that these findings are a prerequisite for recognition by ESMA. SIFMA member firms trade and provide clearing services on a cross-border basis. Expiration of the current transitional relief absent recognition of certain key third country CCPs will have a significantly detrimental impact on markets, and both EU and U.S. participants, as some products are cleared on only certain CCPs that are subject to the oversight of the U.S. Securities and Exchange Commission (“SEC”), for whom the EC has not yet reached an equivalence determination. In the listed options space, for example, certain impacted EU market participants would be forced to exit the listed U.S. equities options markets in the U.S., and in some instances, the underlying U.S. equities markets as well, given the significant capital charges they would incur for clearing options on a non-QCCP. Such a result stands to undermine regulatory risk mitigation goals, decreasing liquidity and widening bid-ask spreads in this market, and pushing market participants to non-cleared equity options markets. We encourage the EC, ESMA and the SEC to conclude equivalence determinations as soon as possible. As the EC continues its ongoing efforts towards equivalence determinations, SIFMA believes that extending the transitional provisions under the CRR is necessary to avoid these detrimental outcomes and ensure continuous access to these markets during this important process. We appreciate the opportunity to provide comments supporting the extension, and welcome any questions you may have regarding the foregoing. *** SIFMA is the voice of the U.S. securities industry. We represent the broker-dealers, banks and asset managers whose nearly 1 million employees provide access to the capital markets, raising over $2.5 trillion for businesses and municipalities in the U.S., serving clients with over $20 trillion in assets and managing more than $67 trillion in assets for individual and institutional clients including mutual funds and retirement plans. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA). For more information, visit http://www.sifma.org.
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Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis), Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

12 Oct 2016 · EU-US Financial Regulatory Framework; MiFID; Brexit

Meeting with Valdis Dombrovskis (Vice-President) and

5 Oct 2016 · EU-US cooperation in the field of financial services

Meeting with Valdis Dombrovskis (Vice-President)

18 Jul 2016 · Resilient financial markets - shaping the rules together

Meeting with Jonathan Hill (Commissioner)

21 Jun 2016 · EU US Financial Markets Issues

Meeting with Jon Nyman (Cabinet of Vice-President Cecilia Malmström)

18 Feb 2015 · Financial services regulation in TTIP

Meeting with Chantal Hughes (Cabinet of Commissioner Jonathan Hill)

18 Feb 2015 · Preparation for Commissioner Hill's speech at SIFMA in Washington on 27 February

Meeting with Nathalie De Basaldua Lemarchand (Cabinet of Commissioner Jonathan Hill)

20 Jan 2015 · Introductory Meeting