GFMA FX Division Submits Letter to EC on Intragroup Margin Exemption Under EMIR

GFMA FX Division, AFME and ISDA Submit Comments to ESMA on Outstanding Uncertainties in the MiFIR Post‐Trade Transparency Framework 

The Global Foreign Exchange Division (GFXD) of GFMA provides comments to European Securities and Markets Authority (ESMA) on the MiFID II/MiFIR Discussion/Consultation Papers issued by ESMA on the 22 May 2014.

Additional information:
AFME Response to the Discussion and Consultation Papers

The Global Foreign Exchange Division (GFXD) of the GFMA Signs Joint Association Letter to the European Commission on EMIR Trade Reporting.

GFMA FX Division Submits Comments to ESMA on its Consultation on Draft RTS on Package Orders under MiFI.

The Global Foreign Exchange Division (GFXD) of the GFMA provides comments to European Securities and Markets Authority (ESMA) on its Discussion Paper on the Trading Obligation for Derivatives under MiFIR

The Global Foreign Exchange Division (GFXD) of GFMA provides comments to the  European Securities and Markets Authority (ESMA) on the questions listed in the ESMA Addendum Consultation Paper on MiFID II/MiFIR (Issued on the 18 February 2015).

The Global Foreign Exchange Division (GFXD) of GFMA provides comments to the European Securities and Markets Authority (ESMA) in response to the Discussion Paper on the Clearing Obligation under the European Market Infrastructure Regulation (EMIR), ESMA/2013/926. 

Given the global nature of the Foreign Exchange (FX) market, GFMA emphasizes the importance in ensuring that the regulatory treatment of FX products in multiple, global jurisdictions remains consistent. GFMA shares its recommendations are responses to questions including the detailed rationale behind the exemption to any central clearing obligation of deliverable over-the-counter (OTC) FX forwards and swaps by the U.S. Department of Treasury. GFMA strongly recommends that ESMA follow a similar approach by not issuing a clearing obligation for such products.

GFMA's European affiliate, the Association for Financial Markets in Europe (AFME), authored a briefing note on the European Commission's 2010 review of the Markets in Financial Instruments Directive (MiFID), specifically in regards to transparency in foreign exchange derivatives.

Background: 

As part of its 2010 review of the Markets in Financial Instruments Directive (MiFID), the European Commission is expected to propose legislation extending transparency requirements into the non‐equities markets. The Committee of European Securities Regulators (CESR) will provide technical advice to the Commission in the context of non‐equities markets transparency and has consulted on the following markets: Corporate Bonds, Structured Finance products (ABS and CDOs), Credit Default Swaps (CDS) and Derivatives (Interest Rate, Equity, Commodities and Foreign Exchange).

AFME’s general position on all aspects of non‐equities transparency apart from structured finance is set out in Briefing Paper [BN10‐03]. This paper specifically covers the market in Foreign Exchange (FX) Derivatives.