Position papers

Position on the Review of the Prudential Framework for Investment Firms

Created: Thursday, 08 March 2018 10:41

We welcome 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 different capital and prudential requirements to the respective classes. However, we have strong concerns regarding the potential impact of the proposals on market makers and liquidity providers,

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Response to EC's Consultation: Building a Proportionate Regulatory Environment to Support SME Listing'

Created: Tuesday, 27 February 2018 14:28

We fully support the European Commission’s commitment to deliver a more conducive regulatory environment to support SME initial public offerings and

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Response to ESMA consultation on Product Intervention Powers (CFDs and Binary Options)

Created: Monday, 05 February 2018 13:37

FESE generally agrees with the elements proposed by ESMA to identify CFDs and binary options. However, we would like to point out that the definitions, in particular in the case of CFDs, are quite broad and could unwittingly capture financial instruments which ESMA did not intend to subject to additional investor protection measures.

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FESE Position Paper: Amendments to the European System of Financial Supervision and the Review of the European Supervisory Authorities

Created: Thursday, 25 January 2018 12:54

FESE welcomes the opportunity to provide its views on the Review of the European Supervisory Authorities. In considering the proposals from the European Commission on the ESAs Review, FESE believes the focus should be on the following high-level principles

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Response to ESMA Consultation on RTS 1

Created: Wednesday, 24 January 2018 08:44

FESE strongly supports ESMA’s proposal to clarify that Systematic Internalisers’ quotes would only reflect prevailing market conditions where the price levels could be traded on a trading venue at the time of publication. We welcome ESMA’s initiative to clarify this issue which we consider to be a necessary development in order to deliver on the objectives of MiFID II/MiFIR and therefore urge ESMA and the Commission to move speedily to adopt this amendment to the Level 2 framework.

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