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24-Feb-2023 FIA responds to EMIR 3.0 proposal and prudential requirements FIA supports many elements in the proposal, which will improve the competitiveness and attractiveness of EU CCPs. However, the EMIR 3.0 package also contains proposals that may ultimately negatively impact the competitiveness of EU firms, harm the efficiency and resiliency of the clearing ecosystem, and impact EU investors and pension funds. Request summary
8-Mar-2023 FIA's CEO Walt Lukken speaks on cyber resilience before CFTC Remarks by FIA President and CEO Walt Lukken before the US Commodity Futures Trading Commission's Market Risk Advisory Committee on 8 March 2023 in Washington, D.C.  As prepared for delivery. Request summary
8-Mar-2023 FIA's CEO Walt Lukken speaks on cyber resilience before CFTC Remarks by FIA President and CEO Walt Lukken before the US Commodity Futures Trading Commission's Market Risk Advisory Committee on 8 March 2023 in Washington, D.C.  As prepared for delivery. Request summary
29-Mar-2023 Trade associations respond to European Commission's call for evidence on the EU Benchmarks Regulation FIA has joined a group of trade associations in a response to the European Commission's call for evidence on the "Review of the scope and third-country regime of the EU Benchmarks Regulation". The associations strongly support the proposal that only systemically important EU and third-country benchmarks that have been positively designated by the European Commission should be in scope of BMR for mandatory compliance. This approach ensures the highest level of certainty and visibility for users and administrators of benchmarks. The criteria that must be satisfied in order to make a positive designation are critical and discussed in some detail in the response. Request summary
5-Apr-2023 FIA files position paper on proposed MiFID II/MiFIR changes in relation to commodities FIA and six other trade associations have jointly submitted a position paper to the European Commission, the European Parliament and a number of member states of the Council in relation to commodities and commodity derivatives ahead of a trilogue process on proposed amendments to MiFIR and MiFID that will commence on 18 April. Request summary
19-Apr-2023 FIA joins industry voices expressing concerns with FTC’s proposed ban on non-competes FIA has filed comments with the US Federal Trade Commission raising concerns with its proposal to enact a near-categorical ban on non-compete provisions in U.S employment agreements.   Request summary
22-Apr-2023 FIA responds to CSRC consultation paper on draft rules on the supervision and administration of futures companies FIA makes three key observations and suggestions in its submitted comments to the China Securities Regulatory Commission’s consultation paper on draft Measures for the Supervision and Administration of Futures Companies. Request summary
22-Apr-2023 FIA responds to CSRC consultation paper on draft rules on the supervision and administration of futures companies FIA makes three key observations and suggestions in its submitted comments to the China Securities Regulatory Commission’s consultation paper on draft Measures for the Supervision and Administration of Futures Companies. Request summary
10-May-2023 FIA warns proposed SEC safeguarding rule may harm FCMs, advisers and customers FIA has filed comments with the US Securities and Exchange Commission (SEC) on a proposal that would replace its existing custody rule. FIA’s comment letter highlights the proposed rule’s potential harms to Futures Commission Merchants (FCMs), registered investment advisers (RIAs) and their underlying customers. Request summary
16-May-2023 FIA responds to EC consultation on REMIT FIA, jointly with FIA EPTA and ISDA, has responded to the European Commission’s “Have your Say” on Wholesale energy markets – improving EU protection against market manipulation. This review of REMIT is being discussed by co-legislators alongside a review of the EU’s Electricity Market Design. In the response, the associations voice their concerns regarding several of the draft amendments in the legislative proposal. Request summary
16-May-2023 FIA responds to EC consultation on REMIT FIA, jointly with FIA EPTA and ISDA, has responded to the European Commission’s “Have your Say” on Wholesale energy markets – improving EU protection against market manipulation. This review of REMIT is being discussed by co-legislators alongside a review of the EU’s Electricity Market Design. In the response, the associations voice their concerns regarding several of the draft amendments in the legislative proposal. Request summary
18-May-2023 FIA defends importance of settlement and price discovery in Texas court filing FIA has filed an amicus brief with the Supreme Court of Texas in the case of Public Utility Commission of Texas v. Luminant Energy Company, stressing the importance of finality of settlement and price discovery in Texas’ wholesale electricity and related derivatives markets.  Request summary
18-May-2023 FIA defends importance of settlement and price discovery in Texas court filing FIA has filed an amicus brief with the Supreme Court of Texas in the case of Public Utility Commission of Texas v. Luminant Energy Company, stressing the importance of finality of settlement and price discovery in Texas’ wholesale electricity and related derivatives markets.  Request summary
23-May-2023 Keeping derivatives markets "open and safe for the real economy" Opening remarks of Walt Lukken, President and CEO of FIA, at the FIA Forum in Brussels, on 23 May2023. As prepared for delivery. Request summary
6-Jun-2023 FIA CEO Lukken testifies on "Future of Digital Assets" before US House Ag Committee Testimony from FIA President and CEO Walter L. Lukken before the US House of Representatives Committee on Agriculture on 6 June, 2023, for its hearing titled "The Future of Digital Assets: Providing Clarity for Digital Asset Spot Markets.”  Request summary
6-Jun-2023 FIA CEO Lukken testifies on "Future of Digital Assets" before US House Ag Committee Testimony from FIA President and CEO Walter L. Lukken before the US House of Representatives Committee on Agriculture on 6 June, 2023, for its hearing titled "The Future of Digital Assets: Providing Clarity for Digital Asset Spot Markets.”  Request summary
20-Jun-2023 'Trust is foundational to open and accessible markets' Opening remarks of Walt Lukken, President and CEO of FIA, at the International Derivatitves Expo in London on 20 June 2023.  Request summary
27-Jun-2023 FIA welcomes EU-UK MoU on regulatory cooperation in financial services  "Cleared derivatives markets are truly global and know no boundaries, so FIA is pleased to see this MoU as a tangible sign of the commitment between the EU and UK to work together and usher in a renewed era of cooperation," said FIA President and CEO Walt Lukken. Request summary
30-Jun-2023 FIA suggests alternative framework for CFTC to clarify separate account margining FIA has filed comments with the US Commodity Futures Trading Commission supporting the agency’s efforts to codify relief that market participants have come to rely on in offering separate account margining to customers while recommending that the CFTC take a different approach to adopting the relevant requirements in its rules. Request summary
14-Jul-2023 FIA responds to LME rulebook consultation FIA has issued its response to the LME consultation on initial action plan proposals and proposed miscellaneous amendments to the LME rulebook and LME Clear rulebook. While FIA generally supports the proposed changes, it highlighted that some LME Rulebook changes could pose legal challenges and raise concern regarding confidentiality treatment. FIA recommends further clarifications and consistency of approach with other exchanges. Request summary
14-Jul-2023 FIA responds to LME rulebook consultation FIA has issued its response to the LME consultation on initial action plan proposals and proposed miscellaneous amendments to the LME rulebook and LME Clear rulebook. While FIA generally supports the proposed changes, it highlighted that some LME Rulebook changes could pose legal challenges and raise concern regarding confidentiality treatment. FIA recommends further clarifications and consistency of approach with other exchanges. Request summary
17-Jul-2023 FIA and ISDA respond to SEC consultation on clearing agency recovery and wind-down plans The Futures Industry Association (FIA) along with the International Swaps and Derivatives Association (ISDA) has  submitted comments on the Security Exchange Commission's (SEC) proposed rulemaking regarding Clearing Agency Resilience and Recovery and Wind-Down Plans. Request summary
31-Jul-2023 FIA responds to the IOSCO consultation on crypto-asset regulation FIA has filed a response to a consultation report on policy recommendations for crypto and digital asset markets from the Board of International Organization of Securities Commissions (IOSCO).  Request summary
28-Aug-2023 FIA responds to CFTC proposed rule on Part 17 Large Trader Reporting FIA has submitted a response to the Commodity Futures Trading Commission’s Large Trader Reporting Requirements Notice of Proposed Rulemaking and accompanying Guidebook. Request summary
7-Sep-2023 Trade associations call for deletion of active account proposal FIA and ten other trade associations have urged EU policymakers to delete the Active Account Requirement proposed in EMIR 3.0. The associations, which represent European end users of derivatives along with providers of clearing services, highlight the detrimental implications of the proposed requirement on EU capital markets, including fragmentation, loss of netting benefits, and making the EU less resilient to market stresses with no benefit to EU financial stability. Request summary
11-Sep-2023 FIA responds to DORA Level 2 consultations FIA has responded to the European Supervisory Authorities’ consultations on the first batch of policy products under the Digital Operational Resilience Act (DORA). While FIA generally supports the ESAs’ proposed changes, the responses highlight remaining industry concerns and areas where more clarity is needed. Request summary
11-Sep-2023 FIA responds to DORA Level 2 consultations FIA has responded to the European Supervisory Authorities’ consultations on the first batch of policy products under the Digital Operational Resilience Act (DORA). While FIA generally supports the ESAs’ proposed changes, the responses highlight remaining industry concerns and areas where more clarity is needed. Request summary
12-Sep-2023 FIA signs letter to SEC on negative impacts of Safeguarding Advisory Client Assets proposal FIA has joined with a diverse set of trade associations –  26 in total – in sending a letter to US Securities and Exchange Commission Chair Gary Gensler urging the SEC not to adopt the Safeguarding Advisory Client Assets proposed rule in its current form. Request summary
18-Sep-2023 FIA responds to CFTC risk management proposals for FCMs FIA has filed a comment letter responding to the Commodity Futures Trading Commission’s advanced notice of proposed rulemaking on risk management program (RMP) regulations for futures commission merchants and swap dealers. Request summary
18-Sep-2023 FIA responds to CFTC risk management proposals for FCMs FIA has filed a comment letter responding to the Commodity Futures Trading Commission’s advanced notice of proposed rulemaking on risk management program (RMP) regulations for futures commission merchants and swap dealers. Request summary
26-Sep-2023 FIA and ISDA respond to CFTC recovery and wind-down plans for DCOs FIA and ISDA have responded to the Commodity Futures Trading Commission's notice of proposed rulemaking on recovery and orderly wind-down plans for derivatives clearing organizations. The associations welcome the CFTC proposal and make several recommendations. Request summary
26-Sep-2023 FIA and ISDA respond to CFTC recovery and wind-down plans for DCOs FIA and ISDA have responded to the Commodity Futures Trading Commission's notice of proposed rulemaking on recovery and orderly wind-down plans for derivatives clearing organizations. The associations welcome the CFTC proposal and make several recommendations. Request summary
26-Sep-2023 FIA highlights best practices for exchange volatility control mechanisms in new report FIA  has released a comprehensive paper, "Best Practices for Exchange Volatility Control Mechanisms," which provides essential guidance for designing robust Volatility Control Mechanisms (VCMs) at derivatives exchanges.  Request summary
28-Sep-2023 FIA issues recommendations for strengthening cyber resilience FIA today released a report that contains lessons learned from a recent cyber incident and sets out six recommendations for improving the derivatives industry's ability to withstand future attacks. Request summary
29-Sep-2023 FIA submits comments to CFTC on self-regulatory process and affiliations The Futures Industry Association (FIA) has responded to a request for comment by the US Commodity Futures Trading Commission regarding the impact of affiliations between certain CFTC-regulated entities, and the potential conflicts of interest that could arise under the current self-regulatory process. Request summary
2-Oct-2023 Building the foundations for successful derivatives markets FIA President and CEO Walt Lukken's opening remarks at FIA Expo 2023 discuss the importance of building a strong foundation for the future of exchange-traded derivatives markets. Request summary
24-Oct-2023 Trade associations submit letter on Article 9 of REMIT FIA and several other trade associations have sent a letter to trilogue parties regarding proposed changes to Art. 9 of the Regulation on Wholesale Energy Market Integrity and Transparency (REMIT) concerning the supervision of third country firms. The associations urge legislators to adopt the least burdensome of the pending proposals, which would have third-country firms designate a representative to respond to requests for information. This contrasts with having to establish an office or move principal trading operations to the EU, which would create considerable market access barriers. Request summary
24-Oct-2023 Trade associations submit letter on Article 9 of REMIT FIA and several other trade associations have sent a letter to trilogue parties regarding proposed changes to Art. 9 of the Regulation on Wholesale Energy Market Integrity and Transparency (REMIT) concerning the supervision of third country firms. The associations urge legislators to adopt the least burdensome of the pending proposals, which would have third-country firms designate a representative to respond to requests for information. This contrasts with having to establish an office or move principal trading operations to the EU, which would create considerable market access barriers. Request summary
31-Oct-2023 FIA voices continued opposition to SEC’s proposed custody rules for FCMs FIA has filed additional comments opposing application of the US Securities and Exchange Commission’s proposed “safeguarding” rule to FCMs. The SEC recently re-opened the public comment period on the proposal, which would replace its existing custody rule for qualified custodians, including FCMs. Request summary
3-Nov-2023 FIA responds to CFTC proposed rulemaking on Provisions Common to Registered Entities FIA and ISDA have submitted a response to the CFTC proposed rulemaking on provisions to common registered entities. The proposal makes technical amendments to the CFTC rules governing how designated contract markets, derivatives clearing organizations, and swap execution facilities certify new rules and products, and the CFTC’s review and processing of such submissions. Request summary
3-Nov-2023 FIA responds to CFTC proposed rulemaking on Provisions Common to Registered Entities FIA and ISDA have submitted a response to the CFTC proposed rulemaking on provisions to common registered entities. The proposal makes technical amendments to the CFTC rules governing how designated contract markets, derivatives clearing organizations, and swap execution facilities certify new rules and products, and the CFTC’s review and processing of such submissions. Request summary
6-Nov-2023 FIA submits comments to SGX on proposed changes to Futures Trading Rules FIA has responded to the Singapore Exchange's consultation on proposed changes to its Futures Trading Rules and other rulebooks. While FIA generally supports the proposed changes, it also makes some recommendations and raises concerns about several proposals. Request summary
6-Nov-2023 FIA submits comments to SGX on proposed changes to Futures Trading Rules FIA has responded to the Singapore Exchange's consultation on proposed changes to its Futures Trading Rules and other rulebooks. While FIA generally supports the proposed changes, it also makes some recommendations and raises concerns about several proposals. Request summary
13-Nov-2023 FIA files comment letter in support of updating CFTC Rule 48.4 The FIA has filed a letter with the CFTC in support of a petition for rulemaking filed by Eurex requesting a technical update to CFTC Rule 48.4. Specifically, the FIA supported an expansion to the rule to permit U.S.-based IBs direct access to Foreign Boards of Trade. Request summary
13-Nov-2023 FIA files comment letter in support of updating CFTC Rule 48.4 The FIA has filed a letter with the CFTC in support of a petition for rulemaking filed by Eurex requesting a technical update to CFTC Rule 48.4. Specifically, the FIA supported an expansion to the rule to permit U.S.-based IBs direct access to Foreign Boards of Trade. Request summary
20-Nov-2023 FIA responds to Bank of England approach to discretionary payments by CCPs FIA and ISDA have responded to the Bank of England's proposed statement of policy on discretionary payments by CCPs. The associations support the proposal but note they would welcome further guidance on how the BoE intends to consider the maintenance of public confidence in the UK financial system when using other supervisory and resolution powers. Request summary
20-Nov-2023 FIA responds to Bank of England approach to discretionary payments by CCPs FIA and ISDA have responded to the Bank of England's proposed statement of policy on discretionary payments by CCPs. The associations support the proposal but note they would welcome further guidance on how the BoE intends to consider the maintenance of public confidence in the UK financial system when using other supervisory and resolution powers. Request summary
20-Nov-2023 FIA responds to FSB consultation on CCP resolution financial resources and tools FIA, IIF, and ISDA have responded to the Financial Stability Board's consultation report on financial resources and tools for CCP resolution. The response emphasises key concerns regarding the proposed approach, citing the need for increased transparency and predictability in resolution scenarios. Request summary
20-Nov-2023 FIA responds to FSB consultation on CCP resolution financial resources and tools FIA, IIF, and ISDA have responded to the Financial Stability Board's consultation report on financial resources and tools for CCP resolution. The response emphasises key concerns regarding the proposed approach, citing the need for increased transparency and predictability in resolution scenarios. Request summary
22-Nov-2023 FIA joins industry call for adequate implementation time for REMIT II FIA along with AFME, CMC Europe, EFET, Eurelectric, Eurogas, Europex, FESE, FIA EPTA, IOGP and ISDA has submitted a letter to European co-legislators urging them to delay the timing of the implementation of some of the obligations of the revised Regulation on Wholesale Energy Market Integrity and Transparency (REMIT II). Request summary
22-Nov-2023 FIA joins industry call for adequate implementation time for REMIT II FIA along with AFME, CMC Europe, EFET, Eurelectric, Eurogas, Europex, FESE, FIA EPTA, IOGP and ISDA has submitted a letter to European co-legislators urging them to delay the timing of the implementation of some of the obligations of the revised Regulation on Wholesale Energy Market Integrity and Transparency (REMIT II). Request summary
29-Nov-2023 Down-payments to modernizing our industry Opening remarks of Walt Lukken, President and CEO of FIA, at the Asia Derivatives Conference in Singapore on 29 November 2023. Request summary
16-Jan-2024 FIA and SIFMA comment on operational risk elements of Basel III proposal FIA joined with the Securities Industry and Financial Markets Association in submitting a comment letter to US banking regulators regarding the operational risk elements of their proposed changes to US bank capital requirements. Request summary
16-Jan-2024 FIA files comment letter opposing GSIB Surcharge Proposal FIA filed a comment letter today with the Board of Governors of the Federal Reserve System expressing serious concerns with the significant increase in capital requirements for client derivatives clearing activities that the Board has proposed in its GSIB Surcharge Proposals. The changes would, on their own, increase the capital required to engage in client clearing activities by more than 58%. Request summary
16-Jan-2024 FIA files comment letter opposing GSIB Surcharge Proposal FIA filed a comment letter today with the Board of Governors of the Federal Reserve System expressing serious concerns with the significant increase in capital requirements for client derivatives clearing activities that the Board has proposed in its GSIB Surcharge Proposals. The changes would, on their own, increase the capital required to engage in client clearing activities by more than 58%. Request summary
16-Jan-2024 FIA strongly opposes provisions in Basel III Endgame Proposal FIA strongly opposes provisions in the Basel III Endgame Proposal put forward by US bank regulators. In letters filed today with the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency, FIA outlines its concerns, stating that the proposals would dramatically increase capital requirements for derivatives clearing services that banks offer to their clients.  Request summary
16-Jan-2024 FIA and SIFMA comment on operational risk elements of Basel III proposal FIA joined with the Securities Industry and Financial Markets Association in submitting a comment letter to US banking regulators regarding the operational risk elements of their proposed changes to US bank capital requirements. Request summary
16-Jan-2024 FIA strongly opposes provisions in Basel III Endgame Proposal FIA strongly opposes provisions in the Basel III Endgame Proposal put forward by US bank regulators. In letters filed today with the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency, FIA outlines its concerns, stating that the proposals would dramatically increase capital requirements for derivatives clearing services that banks offer to their clients.  Request summary
18-Jan-2024 FIA and CME respond to CFTC proposed rulemaking on investments for FCMs and DCOs FIA and CME respond to CFTC proposed rulemaking on investments for FCMs and DCOs Request summary
22-Jan-2024 FIA and ISDA recommend changes to Singapore’s capital framework for clearinghouses On January 22, FIA and ISDA jointly responded to a consultation from the Monetary Authority of Singapore on proposed amendments to the capital framework for approved exchanges and approved clearinghouses. Request summary
26-Jan-2024 FIA Responds to HKEX Proposal on Severe Weather Trading FIA has submitted its response to HKEX’s Proposal on Severe Weather Trading of Hong Kong Securities and Derivatives Markets. FIA expresses its full support for the proposal and highlights that adequate settlement bank support, full capacity operations, ETD vendor participation and give-up processing should be in place to ensure the initiative's success. Request summary
26-Jan-2024 FIA Responds to HKEX Proposal on Severe Weather Trading FIA has submitted its response to HKEX’s Proposal on Severe Weather Trading of Hong Kong Securities and Derivatives Markets. FIA expresses its full support for the proposal and highlights that adequate settlement bank support, full capacity operations, ETD vendor participation and give-up processing should be in place to ensure the initiative's success. Request summary
30-Jan-2024 Joint industry response to European Commission's Call for Feedback on BMR FIA has submitted a joint response with GFMA and ISDA to the European Commission’s Call for Feedback on the review of the scope and regime for non-EU benchmarks. The response sets out the associations’ comments on the EC’s proposal, along with potential draft amendments where possible, and some additional revisions that are considered to support the EC’s aims. Request summary
30-Jan-2024 Joint industry response to European Commission's Call for Feedback on BMR FIA has submitted a joint response with GFMA and ISDA to the European Commission’s Call for Feedback on the review of the scope and regime for non-EU benchmarks. The response sets out the associations’ comments on the EC’s proposal, along with potential draft amendments where possible, and some additional revisions that are considered to support the EC’s aims. Request summary
31-Jan-2024 FIA responds to LME consultation on Daily Price Limits FIA has responded to the London Metal Exchanges's consultation on Daily Price Limits (DPLs). While supporting the LME's goal of creating a transparent market suspension framework based on consecutive DPLs, the response raises crucial considerations such as the impact on trading and clearing, trade confirmation processes, and the importance of clear communication. Request summary
31-Jan-2024 FIA responds to LME consultation on Daily Price Limits FIA has responded to the London Metal Exchanges's consultation on Daily Price Limits (DPLs). While supporting the LME's goal of creating a transparent market suspension framework based on consecutive DPLs, the response raises crucial considerations such as the impact on trading and clearing, trade confirmation processes, and the importance of clear communication. Request summary
7-Feb-2024 FIA response to provisional EMIR 3.0. agreement FIA congratulates the Council of the EU and the European Parliament on reaching a provisional political agreement on the review of the European market infrastructure regulation and directive (EMIR 3.0). FIA supports positive incentives to further enhance the attractiveness of EU clearing and EU capital markets. However, FIA remains convinced that any measures to increase the attractiveness of EU clearing should be guided by the principle of facilitating client choice on where to clear and protecting the international competitiveness of EU market participants. Request summary
9-Feb-2024 FIA and ISDA respond to Australia FMI regulatory reforms consultation FIA and ISDA have submitted a response to the Australian Treasury's consultation on the financial market infrastructure reform package. In particular, the associations have carefully considered the proposed crisis resolution regime. Request summary
16-Feb-2024 FIA responds to CFTC guidance on the listing of voluntary carbon credit derivatives The Commodity Futures Trading Commission's proposed guidance on voluntary carbon markets is a welcome attempt to strengthen the integrity of these markets, FIA says in a response to the proposal. However, if the CFTC intends to establish additional requirements for exchanges that list derivatives on carbon credits, it should engage in a formal rulemaking process. Request summary
16-Feb-2024 FIA responds to FCA commodities consultation CP23/27 FIA has submitted a response to the FCA’s commodity consultation. The FCA proposals are based on the UK’s wholesale markets review, initiated by HM Treasury in 2021. While FIA supports FCA’s goals of promoting market integrity and resilience, it is concerned about FCA’s proposed approach to the ancillary activities exemption. Request summary
1-Mar-2024 FIA supports IOSCO’s good practices for voluntary carbon markets On 1 March FIA responded to a public consultation issued by the International Organization of Securities Commissions outlining a proposed set of “good practices” to promote the integrity and orderly functioning of voluntary carbon markets (VCMs). In the response, FIA commended IOSCO for fostering a much-needed dialogue on the issues surrounding the development of VCMs. Request summary
4-Mar-2024 FIA responds to second batch of DORA policy products FIA and FIA EPTA have submitted responses to three consultations issued by the European Supervisory Authorities on the second batch of policy products under the EU Digital Operational Resilience Act (DORA). The consultations cover regulatory technical standards on the subcontracting of information and communication technology (ICT) services, content, timelines and templates for incident reporting, and threat-led penetration testing. Request summary
6-Mar-2024 FIA responds to FCA consultation on derivatives markets transparency FIA welcomes the Financial Conduct Authority’s proposals regarding the revised bond and derivative transparency regime in the UK. Resilient and robust markets are of key importance to FIA members and FIA supports the consultation’s stated aim of streamlining transparency requirements so that they better reflect the nature and depth of liquidity in the market.  Request summary
11-Mar-2024 Competing with conviction, respecting the contest Opening remarks of Walt Lukken, President and CEO of FIA, at the International Futures Industry Conference in Boca Raton, FL. As prepared for delivery. Request summary
15-Mar-2024 FIA responds to consultation on critical third parties in the UK financial sector FIA supports the UK authorities’ proposed approach, allowing regulators to build on and complement operational resilience frameworks for firms and financial market infrastructures. FIA members also support the proposal for oversight of critical third parties to be as interoperable as reasonably practicable with similar existing and future regimes. Furthermore, FIA members support the proposals to promote regulatory and supervisory interoperability. Request summary
19-Mar-2024 FIA urges CFTC to fill gaps in customer protections before approving leveraged direct clearing FIA has filed comments with the Commodity Futures Trading Commission on its proposed rulemaking related to the protection of clearing member funds held by designated clearing organizations. Request summary
28-Mar-2024 FIA responds to FCA, BoE draft guidance on UK EMIR reporting requirements FIA has responded to the UK Financial Conduct Authority and Bank of England’s consultation setting out draft questions and answers as guidance to support the implementation of revised UK EMIR reporting requirements that go live on 30 September 2024. Request summary
28-Mar-2024 FIA joins response to BCBS consultation on bank exposures to cryptoassets FIA has joined with several other trade associations in responding to the Basel Committee on Banking Supervision’s (BCBS) consultative document on amendments to its standard for bank exposures to cryptoassets. Request summary
1-Apr-2024 FIA responds to CFTC proposal on FCM operational resilience framework FIA has submitted a response to the CFTC’s proposed rule requiring an operational resilience framework for futures commission merchants.  Request summary
9-Apr-2024 European T+1 Industry Task Force responds to UK report FIA has joined several industry associations in welcoming a recent UK report on moving to T+1 settlement. Request summary
16-Apr-2024 FIA calls on international regulators to continue progress on margin transparency FIA has filed a letter with international standard-setting bodies urging further progress on efforts to increase the resilience of global derivatives markets in times of stress. The letter was submitted in response to a consultation on initial margin requirements in centrally cleared derivatives markets that was issued by Basel Committee on Banking Supervision (BCBS), the Bank for International Settlements' Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO). Request summary
19-Apr-2024 FIA responds to FICC access and segregation proposals FIA has responded to the Fixed Income Clearing Corporation’s proposals to revise its customer clearing access models and to modify its margin segregation rules in order to implement the SEC’s new clearing mandate for U.S. Treasuries. FIA's response identifies conflicts between the proposed access structures and CFTC rules to which FCMs are subject. Request summary
19-Apr-2024 FIA responds to JSCC consultation on initial margin and clearing fund calculation methods  FIA has submitted a response to the Japan Securities Clearing Corporation’s consultation, which proposes to introduce stress add-on initial margin charges and a partial revision of the clearing fund calculation method in its listed financial derivatives clearing service. Request summary
22-Apr-2024 FIA responds to CFTC proposed rulemaking on FCM separate account margining FCMs are currently relying on no-action relief that allows them to separately margin accounts of the same beneficial owner. This rule marks the second attempt by the CFTC to codify that relief. FIA’s letter asks the CFTC to codify the relief as written without laying on additional highly prescriptive requirements that limit FCM discretion to risk manage accounts. Request summary
22-Apr-2024 FIA responds to CFTC Foreign Boards of Trade proposed rulemaking Under current rules, US-based commodity pool operators, commodity trading advisers, futures commission merchants and prop firms can directly access Foreign Boards of Trade. The pending rule would include US-based introducing brokers among the permissioned registrants. FIA’s letter supports the proposed expansion, noting that adding introducing brokers to the mix should provide more brokerage options for US customers and promote liquidity in foreign products. Request summary
24-Apr-2024 FIA cautions CFTC on regulation of AI FIA has urged the CFTC to take a "technology-neutral" approach and focus on "outcomes and use cases" rather than the technology itself. FIA also urged the CFTC to consider the applicability of its existing rules and regulations before presupposing that new, AI-specific regulations are needed. Request summary
30-Apr-2024 FIA responds to FCA proposal on publicising enforcement investigations FIA has responded to the UK Financial Conduct Authority’s public consultation on changes to its approach to enforcement investigations. The proposed changes include the FCA publicly announcing the opening of an investigation and disclosing the identity of the subject of the investigation where it considers this to be in the public interest. FIA is concerned that the proposed approach will be detrimental to the orderly functioning of UK capital markets, with limited value to public interest. Request summary
13-May-2024 FIA asks CFTC to sunset large trader reporting for commodity swaps FIA, joined by ISDA, has responded to the CFTC’s notice of intent to renew the collection of large trader reporting (LTR) data for physical commodity swaps. The associations reiterate and build on requests they have made in recent years for the CFTC to sunset the LTR rules for swaps, which were envisioned as a temporary measure while the CFTC stood up its comprehensive swap reporting framework under Dodd-Frank. Request summary
15-May-2024 FIA backs international effort to promote "effective practices" for variation margin FIA has responded to a discussion paper released by international standard setters that sets out eight "effective practices" for streamlining variation margin in centrally cleared markets. The discussion paper addresses the need for greater transparency and understanding of margin practices at central counterparties, particularly in light of recent episodes of market volatility triggered by the COVID crisis and Russia's invasion of Ukraine.  Request summary
23-May-2024 FIA responds to US FTC’s rule banning nearly all noncompete agreements FIA and FIA Principal Traders Group have filed an amicus brief along with several other financial services trade associations in a case involving the US Federal Trade Commission’s recently issued rule that bans nearly all noncompete agreements in the US. In their brief, the associations highlighted the practical challenges of the rule for the financial industry and warned that it would harm competition and endanger confidential information. Request summary
27-May-2024 FIA responds to B3 Clearing consultation on its recovery plan and early settlement auction FIA has responded to B3 Clearing's consultation proposing to amend rules regarding B3's recovery plan. As part of the recovery plan, the clearinghouse is proposing to include a final auction, giving market participants a last opportunity to assist it in returning to a matched book, as well as early settlement auction or tear-up provisions in case the final auction fails. Request summary
18-Jun-2024 FIA and Acuiti release report on challenges and opportunities for the European listed derivatives markets London and Washington, DC – FIA released a report on the challenges and opportunities facing the European listed derivatives markets on 18 June. The report is based on responses to a survey conducted recently by Acuiti, a market intelligence firm, that gauged industry sentiment regarding the key trends, opportunities and challenges facing the industry in Europe. Request summary
18-Jun-2024 IDX 2024 opening remarks: The industry shines through adversity Opening remarks of Walt Lukken, President and CEO of FIA, at the International Derivatives Expo (IDX) in London on 18 June 2024. As prepared for delivery. Request summary
20-Jun-2024 FIA responds to FSB consultation on Liquidity Preparedness for Margin and Collateral Calls FIA’s response highlights several key points for international standard setters to consider including the importance of margin transparency and simulation tools from Central Counterparties for NBFIs and the need for a balanced regulatory approach to ensure compliance with FSB recommendations without overburdening clearing members. Request summary
24-Jun-2024 FIA opposes California bill that would disrupt carbon markets FIA filed a formal letter of opposition to California SB 1036, which would impede the development of robust and well-regulated voluntary carbon markets (VCMs). The legislation would subject entities that sell, issue, and engage in other activities relating to voluntary carbon offsets to heightened penalties under California law. Request summary
25-Jun-2024 FIA and FIA PTG support legal challenge of US FTC rule banning noncompete agreements FIA and the FIA Principal Traders Group along with several other financial services trade associations have filed an amicus brief in a second case involving the US Federal Trade Commission’s proposed rule that would ban nearly all noncompete agreements in the US. Request summary
5-Jul-2024 FIA responds to CDCC consultation on skin in the game FIA and ISDA have responded to a consultation from the Canadian Derivatives Clearing Corporation on rule changes regarding skin in the game. Request summary
18-Jul-2024 FIA releases best practices for automated trading risk controls and system safeguards This paper consolidates our previous work and covers best practices in pre-trade risk management, exchange volatility control mechanisms, post-trade analysis and exchange-based conformance testing, among other areas. These practices are designed to help ensure that markets operate safely, regardless of the technology used.  Request summary
18-Jul-2024 FIA and FIA PTG support another legal challenge to US FTC rule banning noncompete agreements FIA and the FIA Principal Traders Group along with several other financial services trade associations filed an amicus brief in a third case involving the US Federal Trade Commission’s final rule that would ban nearly all noncompete agreements in the US. Request summary
25-Jul-2024 FIA CEO testifies at House Agriculture Committee hearing Walt Lukken, President and CEO of FIA, testified today at a US House Agriculture Committee subcommittee hearing on reauthorizing the Commodities Futures Trading Commission (CFTC). Request summary
26-Jul-2024 FIA calls for DORA supervisory guidance ahead of January 2025 application deadline FIA, together with five other trade associations, has co-signed a joint statement that draws the European Supervisory Authorities’ attention to the challenges that industry participants, including financial entities as well as ICT third-party service providers, are facing regarding the implementation of DORA by the 17 January 2025 deadline. Request summary
26-Jul-2024 FIA responds to ASX proposals on position reporting framework and operating rules FIA has submitted a response to ASX’s consultation paper on proposed changes to the position reporting framework and a review and update of operating rules for ASX 24 and ASX Clear (Futures). Request summary
7-Aug-2024 FIA responds to FICC rules implementing the US Treasury clearing mandate FIA responded to the Fixed Income Clearing Corporation’s (FICC) proposal to implement the SEC’s new clearing mandate for US Treasurys. FIA’s letter urges FICC to provide flexibility for market participants to clear US Treasurys at multiple clearinghouses, as they may arise in the future. Request summary
12-Aug-2024 FIA urges US Treasury Department to remain technology-neutral on AI FIA's letter suggested Treasury focus on the applications of artificial intelligence within the context of a particular use case as opposed to the technology as a whole. Request summary
19-Aug-2024 FIA responds to SEBI consultation on strengthening the index derivatives market FIA supports the underlying intent of SEBI's measures and offers several suggestions to enhance the proposals. Request summary
23-Aug-2024 FIA responds to EBA-ESMA review of the prudential framework for investment firms FIA responded to the EBA-ESMA discussion paper on the European Commission call for advice on the investment firms' prudential framework, noting the importance of ensuring EU IFR/D is fit for purpose and that the application of prudential rules to commodity firms would be inappropriate, unduly complex, disproportionate and limit market entry for many small-size market participants. Request summary
4-Sep-2024 FIA outlines how successful derivatives markets will attract investor interest and support the enhancement of the CMU FIA has published a paper outlining its views on how to support the progress of the European Union’s Capital Markets Union. The paper – Capital Markets Union at a Critical Juncture – sets out the role that derivatives play in effective capital markets. Specifically, FIA believes that centrally cleared derivatives are a key ingredient to building a strong CMU. Request summary
5-Sep-2024 FIA responds to OCC proposed margin add-on charge FIA believes that the current backward-looking, monthly-calibrated margin add-on falls short of providing adequate risk mitigation and should only serve as a temporary measure while a more precise and transparent system is developed. Request summary
6-Sep-2024 FIA responds to Fed proposal to expand operating hours of Fedwire and NSS FIA has written in support of the US Federal Reserve's proposal to expand the operating hours of the Fedwire Funds Service and the National Settlement Service. Request summary