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. 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 believe several elements of the proposals require close scrutiny by the co-legislators to ensure alignment with the Capital Markets Union (CMU) objectives of a simpler, more proportionate prudential regime. We also believe that some aspects of the proposal may need to be adjusted to fully meet key objectives of, and prevent conflict, with MiFID II. We are concerned that, if unchanged, some of the proposed rules may lead to undue compliance costs and barriers to entry which risk diminishing the quality, diversity and competitiveness of European capital markets. In our response we offer suggestions for adjustments to those rules, in order to ensure that investment costs for European companies, investors, and citizens will not unnecessarily increase.
