The FIA European Principal Traders Association (FIA EPTA) represents 27 regulated firms in Europe that trade in financial instruments using their own capital. Many act as market makers in various financial instruments and provide liquidity under a contract for an exchange. Risks are backed by general clearing members and cleared with central counterparties (CCPs) and positions are carefully hedged and monitored to manage market risk. FIA EPTA members do not have clients, do not take deposits and do not hold client money.
We believe the blanket application of the requirements set out in CRD IV to banks and investment firms, without distinguishing between firms by activity or size, will have a disproportionate impact on proprietary trading firms that serve as Europe’s market makers, without enhancing the management of risk.