Letters

Designing a New Prudential Regime for Investment Firms

Summary

SIFMA AMG provided comments to European Banking Authority (EBA) on designing a new prudential regime for investment firms. The current prudential regime applicable to investment firms is outdated and inappropriately tailored for the range of investment firms to which it applies. Our view is that a new regime has the potential to produce a sensible result for investment firms, provided it is designed in a way which appropriately addresses the critical distinctions and operational technicalities of the wide range of investment firms to which it will apply.

While we are broadly supportive of the mandate to redesign the regime, we are concerned that some of the EBA’s proposals are at odds with the unique characteristics of the asset management industry. Specifically, the categorization of investment firms and the capital proxies, which represent the risk of harm to others, together with their associated metrics, are not appropriate for asset management firms.

See also:
EBA seeks views on new prudential regime for investment firms

PDF

Submitted To

European Banking Authority (EBA)

Submitted By

SIFMA AMG

Committee

Asset Management Group (AMG)

Date

2

February

2017