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1、Click here or press enter for the accessibility optimised versionINVESTMENT&CAPITAL MARKETSQ1 2024Click here or press enter for the accessibility optimised versionFOREWORDFrom Galina DimitrovaFOREWORDAs we reflect on the first three months of 2024,I am pleased to share our latest Investmentand Capit

2、al Markets quarterly policy report.This report brings together and highlights thekey achievements and areas of focus for theIAs investment and capital markets activityover the past few months.Access to market data is a key priority for ourmembership,and this report discusses anumber of recent develo

3、pments with regardto the creation of a consolidated tape and theFCAs related consultation on payments todata providers,as well as the FCAs report onits Wholesale Data Market Study.We also continue to actively engage in allrelevant sustainability policy developments,including full support for our mem

4、bers withthe implementation of the FCAs newSustainability Disclosure Requirements(SDR)and investment labels regime,including theupcoming general anti-greenwashing rule,aswell as developments in carbon pricing andsustainability reporting.Additionally,the IAalso published our joint report with PwC onl

5、essons from the first round of reporting fromasset management firms against the FCAsrules on TCFD for asset managers.On the investment operations side,thetransition to T+1 settlement has remained akey focus.The IA has been intensely workingwith members to support firms with the NorthAmerican transit

6、ion,which goes live on 28May.We are also a member of the UKAccelerated Settlement Taskforce,whichrecently issued its report andrecommendations and are closely engagingwith the consideration of T+1 in Europe.Further details on these and many otheraspects of our work are covered in thefollowing sectio

7、ns.We hope that memberscontinue to find this policy report auseful resource and invite anyone keen to findout more to reach out to the team.GALINA DIMITROVADIRECTOR,INVESTMENT ANDCAPITAL MARKETSThe Investment and Capital Markets hubpage can be found here.Click here or press enter for the accessibili

8、ty optimised versionCONTENTSCONTENTSFOREWORDSUSTAINABILITY AND RESPONSIBLE INVESTMENTSDR and Investment Labels Final UpdateTiming considerations for SDR implementationGuidance on the anti-greenwashing ruleApplication of SDR to portfolio managementApplication of SDR to Overseas FundsSFDR ReviewIA/PwC

9、 Report on Asset Manager TCFD ImplementationCarbon and Nature MarketsGreen Finance Strategy:Transition Finance Market Review andNet Zero Blended Finance ProjectMaking Markets:the Citys Role in Industrial StrategyFRC Launches Market Study on UK Sustainability AssuranceMarketTransition Plan Taskforce

10、consultation on asset managerguidanceCONTENTSCAPITAL MARKETSINVESTMENT OPERATIONSDevelopment of Consolidated TapesFCA report on wholesale data marketsImproving Transparency regime for non-equity instrumentsUK Listing RulesElectronic Trading QuestionnairePrivate MarketsCSDR Settlement disciplineT+1 S

11、ettlementEMIR RefitClick here or press enter for the accessibility optimised versionSUSTAINABILITYAND RESPONSIBLEINVESTMENTSUSTAINABILITYANDRESPONSIBLEINVESTMENTSDR AND AND INVESTMENT LABELSUPDATEImplementation of SDR and the investmentlabels continues at pace for firms.TIMING CONSIDERATIONS FOR SDR

12、IMPLEMENTATIONThe IA and Eversheds Sutherland havepublished initial industry guidance on timingconsiderations for SDR implementation.Theguidance illustrates applicable timelines tohelp firms plan by outlining what needs to beprepared for an FCA application,if required,and when.Further IA-Eversheds S

13、utherlandguidance will be produced in the comingmonths,covering more detailedimplementation issues and key and commonquestions that emerge through the IA SDRImplementation Forum.GUIDANCE ON THE ANTI-GREENWASHING RULEThe first incoming deadline is the applicationof the anti-greenwashing rule which co

14、mes into force on 31 May 2024.Despite IA urging theFCA to align implementation date to 2December 2024 when the naming andmarketing rules come into force,the FCA hasconfirmed that the anti-greenwashing rule islaw and will be coming in to force on theplanned date.The FCA has clarified on itswebsite th

15、at firms subject to the naming andmarketing rules for asset managers are notrequired to meet those additionalrequirements until 2 December 2024.We arestill expecting guidance from the FCA on howfirms should apply the anti-greenwashingrule.APPLICATION OF SDR TO PORTFOLIOMANAGEMENTThe FCA will be cons

16、ulting soon on theapplication of SDR to portfolio managementservices and has confirmed at the March IASDR Implementation Forum that theFURTHER INFORMATION:Carol ThomasHead of Sustainability&ResponsibleInvestmentcarol.thomastheia.orgFlora TudhopePolicy Lead,Sustainability&ResponsibleInvestmentflora.t

17、udhopetheia.orgPaul ScapingPublic Policy Specialistpaul.scapingtheia.orgIA website hub page can be found here.application of SDR to pension product is amedium-term ambition.APPLICATION OF SDR TO OVERSEASFUNDSSDR currently does not apply to overseasfunds being marketed into the UK and firmswith overs

18、eas funds cannot voluntarily chooseto apply a SDR label to those funds.UKdistributors will have to place a notice onoverseas funds marketed in the UK to clarifythat they are not subject to the UKsustainability investment labelling anddisclosure requirements.The application ofSDR to overseas funds is

19、 a matter for HMT(not the FCA)and,on request from HMT,theIA is gathering member views on whether ornot SDR should be applied to those overseasfunds being sold to UK investors.SFDR REVIEWWe recently met with the EuropeanCommission to outline key IA positions on therecent SFDR consultation.The Europea

20、nCommission plans to publish in Spring afeedback statement,factually outlining asummary of the over 400 responses receivedto the consultation that feedback statementwill not outline any indication on futuredirection of SFDR.It is clear the EuropeanCommission is keenly observing how SDRimplementation

21、 is going in the UK in order tohelp develop its own position going forwardand we have offered to help facilitatediscussions with our members on experiencesand lessons learned.IA/PWC REPORT ON ASSET MANAGERTCFD IMPLEMENTATIONOn 7 March,the IA published our joint reportwith PwC on the key themes seen

22、in the firstround of reporting from firms against theFCAs rules on TCFD for asset managers.Thereport is intended to serve as a usefulresource to members reporting for June 2024and beyond.The report looks at entity,product,and on-demand reporting,across a selection of assetmanagers who reported for t

23、he first time in2023 against the FCAs requirements.As wellas outlining some of the key challenges facedby asset managers in implementing the FCAsrules,the report also sets out a list of 10 keyFURTHER INFORMATION:Carol ThomasHead of Sustainability&ResponsibleInvestmentcarol.thomastheia.orgFlora Tudho

24、pePolicy Lead,Sustainability&ResponsibleInvestmentflora.tudhopetheia.orgPaul ScapingPublic Policy Specialistpaul.scapingtheia.orgIA website hub page can be found here.areas for asset managers to consider in theirreporting going forward.The IA will also beusing this report to inform our ongoingengage

25、ment with the FCA.CARBON AND NATURE MARKETSThere has been a recent increase in policywork relating to carbon and nature markets,largely because of increasing activity bypolicymakers.In March,the IA responded totwo consultations focused on carbon markets.IOSCO is consulting on the introduction of ase

26、t of advisory good practices for theoperation globally of voluntary carbonmarkets while the UK ETS Authority held aconsultation on enhancement the UKs carboncap and trade scheme.The Government alsoreiterated in the Budget that the UK wouldintroduce a Carbon Border AdjustmentMechanism(a carbon import

27、 tax)and aconsultation on the design of this mechanismwas launched at the end of March.The IAscontribution to all consultations hasemphasised the importance of a reliablecarbon price signal to support long-terminvestment and engagement decisions,whilesupporting greater international alignment,and du

28、e consideration of the potential socialconsequences of using carbon pricing tools.The IAs Paul Scaping also gave evidence inMarch to the UK Parliament EnvironmentalAudit Committee as part of its inquiry into therole of natural capital in the green economy.The evidence session focused on theappropria

29、te metrics and assurance methodsrequired to build confidence in carbon andnature markets.GREEN FINANCE STRATEGY:TRANSITION FINANCE MARKETREVIEW AND NET ZERO BLENDEDFINANCE PROJECTThe IA continues to engage with theGovernment on the delivery of its 2023 GreenFinance Strategy.Most recently this hasfoc

30、used on the launch by the City of LondonCorporation(CoLC)of a call for evidenceinsupport of the Transition Finance MarketReview.The Green Finance Strategy 2023announced that the Government would set upa market-led review to examine how the UKcan offer a better market to access financialFURTHER INFOR

31、MATION:Carol ThomasHead of Sustainability&ResponsibleInvestmentcarol.thomastheia.orgFlora TudhopePolicy Lead,Sustainability&ResponsibleInvestmentflora.tudhopetheia.orgPaul ScapingPublic Policy Specialistpaul.scapingtheia.orgIA website hub page can be found here.services that facilitate the transitio

32、n to netzero.The Transition Finance Market Reviewwas launched in January 2024 and will reportback to the UK Government in the summer.CoLC is providing secretariat support to thisindependent review and the call for evidence,to which the IA will respond,will inform itswork programme and eventualrecomm

33、endations.The Government alsorecently stated that a Net Zero BlendedFinance Project(funding for which wasannounced in November 2023)will aim toimprove the capacity and expertise of theGovernment to explore innovative blendedfinance approaches in mobilising additionalprivate sector investment to supp

34、ort the UKstransition to net zero.The IA has met with theofficials responsible for this project to discusshow we can support it.MAKING MARKETS:THE CITYS ROLE ININDUSTRIAL STRATEGYAn IA-sponsored independent thinktankreport proposing a new partnership betweenthe public and private sectors to finance

35、thetransition to net zero was launched at aparliamentary reception in February.Thereport,published by IPPR and the GreenFinance Institute and titled Making markets:the Citys role in industrial strategy,arguesthat the financial sector can play a key role insupporting the UKs industrial strategy andgr

36、een recovery,by aligning its activities withnational climate targets and providinginnovative financial solutions.The report alsocalls for more public investment to catalyseprivate capital and reduce the risks and costsof green projects.The report launch includedcross-party speeches from Treasury Min

37、isterGareth Davies and Shadow Treasury MinisterTulip Siddiq.Following publication of thereport,we will continue engagement with theparties and officials in preparation for the post-election period.FRC LAUNCHES MARKET STUDY ON UKSUSTAINABILITY ASSURANCEMARKETAs part of its work to promote high-qualit

38、ycorporate reporting and governance,the FRCannounced on 21 March 2024 that it willconduct a market study on sustainabilityassurance services in the UK.The study aimsto assess the effectiveness,quality andFURTHER INFORMATION:Carol ThomasHead of Sustainability&ResponsibleInvestmentcarol.thomastheia.or

39、gFlora TudhopePolicy Lead,Sustainability&ResponsibleInvestmentflora.tudhopetheia.orgPaul ScapingPublic Policy Specialistpaul.scapingtheia.orgIA website hub page can be found petition of this rapidly growing market,which provides assurance over companiessustainability reporting.The FRCs market study

40、will examine thefollowing key areas:The FRC intends to engage with a wide rangeof stakeholders and has also published a setof questions for consultation,which are openfor response until 13 June 2024.The FRCexpects to publish its findings andrecommendations by the end of 2024.We have already had enga

41、gements withmembers on sustainability assurance,including the scope of the information,extentof the assurance(reasonable vs limited),andchoice,quality and competition in thesustainability assurance market,capacity constraints and barriers to entry orexpansion,potential impacts from changinginternati

42、onal regulations,any interplay between the sustainabilityassurance and statutory audit marketsthe importance of interoperability amongstglobal assurance standards and compatibilitywith the ISSB reporting standards.Weoutlined this in our response to the IAASBInternational Standard on SustainabilityAs

43、surance in December 2023.Building uponthis work,we will be producing a consultationresponse to the FRC market study on the UKsustainability assurance market and are in theearly stages of engaging with members onthe emerging themes and concerns in the UKsustainability assurance market.TRANSITION PLAN

44、 TASKFORCECONSULTATION ON ASSET MANAGERGUIDANCEThe IA has responded to the Transition PlanTaskforces(TPT)consultation on AssetManager Sector Guidance.The TPT publishedthis guidance to assist investment managersin interpreting its previously publishedDisclosure Framework.The guidance waspublished as

45、part of a package of sevensector-specific documents intended to helppreparers to interpret the DisclosureFramework for use in their sector.Theguidance will now be updated ahead of theFURTHER INFORMATION:Carol ThomasHead of Sustainability&ResponsibleInvestmentcarol.thomastheia.orgFlora TudhopePolicy

46、Lead,Sustainability&ResponsibleInvestmentflora.tudhopetheia.orgPaul ScapingPublic Policy Specialistpaul.scapingtheia.orgIA website hub page can be found here.end of the TPTs remit in February.Theresponse is available on the IAs website.FURTHER INFORMATION:Carol ThomasHead of Sustainability&Responsib

47、leInvestmentcarol.thomastheia.orgFlora TudhopePolicy Lead,Sustainability&ResponsibleInvestmentflora.tudhopetheia.orgPaul ScapingPublic Policy Specialistpaul.scapingtheia.orgIA website hub page can be found here.Click here or press enter for the accessibility optimised versionCAPITAL MARKETSCAPITALMA

48、RKETSDEVELOPMENT OF CONSOLIDATEDTAPESIn December 2023 the FCA publisheda consultation paper CP23/33 on payments todata providers that will have to give data tothe bond consolidated tape provider.Theconsultation proposes three options onpotential payments to data providers.The IA submitted a response

49、 to thisconsultation on 9th February 2024.Based onthe feedback from members,the IA stronglyopposes payments to data providers.Ourmembers believe it will impact the viability ofa consolidated tape and it will set a precedentfor payment for regulatory compliance.The IA also submitted a joint associati

50、on letterwith AFME and UK Finance stating strongopposition to any payments to data providersfrom the three trade associations.Following the receipt of this consultation,inearly April,the FCA issued a statement statingthat payment to data providers will not berequired.FCA REPORT ON WHOLESALE DATAMARK

51、ETSThe FCA published its report on its WholesaleData Market Study in late February 2024.Thestudy,which was carried out in 2023,looked atcompetition across the provision ofbenchmarks,credit ratings agencies(CRAs)and the provision of market data vendor(MDV)services.The report found no evidence that fi

52、rmscannot access the wholesale data they need,and that in most cases this data is of sufficientquality.Despite noting the data markets areconcentrated with limited competition,theFCA has ruled out significant intervention andhas not referred the market to theCompetition&Markets Authority.The FCA has

53、also stated its market study will informongoing work on developing consolidatedtapes,and will consider using existing powersunder the Competition Act to address specificcompetition issues at firms.FURTHER INFORMATION:Hugo GordonSenior Policy Adviserhugo.gordontheia.orgKenix LeePolicy Leadkenix.leeth

54、eia.orgAnika SchaffterTraineeanika.schafftertheia.orgIA website hub page can be found here.The IA responded to the Market Study lastyear highlighting our industrys significantconcerns at soaring data costs,opaquepricing structures,and restrictive licensingconditions,and called for regulators to make

55、reforms to address these issues.We aredisappointed with these findings and willcontinue to push regulators and policymakersfor further intervention on this topic.IMPROVING TRANSPARENCY REGIMEFOR NON-EQUITY INSTRUMENTSThe FCA published a consultation paperCP23/32 on improving transparency for bondand

56、 derivatives markets in December 2023.The paper proposes grouping sovereignbonds and corporate bonds with a number offactors to allow better separation of veryliquid bonds for which higher transparencyrequirements can apply,from less liquidbonds for which longer deferrals would givethe necessary pro

57、tection.A working group of members from the FixedIncome Trading Committee engaged closelywith AFME members to shape deferralmodels that are acceptable to both the sell-side and the buy-side.The two associationshave reached a significant agreement on aproposal for future UK post-tradetransparency mod

58、el for corporate andsovereign bonds.The proposal forms a corepart of each of our respective CP responses.The proposed hybrid model includes twolarge-in-scale(LIS)thresholds and specificcaps on the transaction volume that ispublished after a 4-week deferral(i.e.a mixbetween the two FCA models),and al

59、soreplaces FCA Model 1s middle tier of deferrals(price reported at 15 minutes and volumereported on T+3),with the reporting of priceand volume at T+2.The IA and AFME has since met with the FCAto further advocate our proposals.UK LISTINGS RULESIn December the FCA published consultationpaper CP23/31 o

60、n proposals to amend theListing Rules,with a view to improving the UKas a listing environment and attracting andretaining more companies to list,grow and dobusiness here.FURTHER INFORMATION:Hugo GordonSenior Policy Adviserhugo.gordontheia.orgKenix LeePolicy Leadkenix.leetheia.orgAnika SchaffterTrain

61、eeanika.schafftertheia.orgIA website hub page can be found here.For the UK to remain globally competitive,innovation is key and in the IAs response wesupported the majority of the FCAs proposals,including their plan to significantly reform theUK listing environment and to create a singlesegment for

62、commercial company issuers ofequity shares,replacing the previous premiumand standard listing categories.However,there are three specific areas withinthis consultation in which the FCA is proposingto remove certain key shareholderprotections,which many IA members areconcerned will diminish investmen

63、t managersability to conduct this vital role in deliveringthe best possible investment outcomes forend investors.These three areas are:In our response we opposed these changes,while also endeavouring to put forwardThe removal of a shareholder vote forsignificant transactions;The removal of a shareho

64、lder vote forRelated Party Transactions;The watering down of Dual Class ShareStructure(DCSS)restrictions.meaningful solutions and alternativemechanisms which will seek to strike a moreappropriate balance between:1.UK competitiveness;2.The needs of companies and their ability toraise capital on publi

65、c markets;3.The obligation on investment managers todeliver sustainable returns and protect thevalue of their clients investments;and4.The needs of society and the economy toensure growth and prosperity,whilemaintaining the integrity of,and confidencein,well-functioning public markets.Specifically:W

66、e propose the retention of shareholdervote for both significant transactions andrelated party transactions,but we suggestthat the FCA could consider potentialincreases to the transaction thresholdsrequiring a shareholder vote,and areduction of certain disclosurerequirements relating to these transac

67、tions,in order to reduce any unnecessary burdenon companies seeking to list in the UK.FURTHER INFORMATION:Hugo GordonSenior Policy Adviserhugo.gordontheia.orgKenix LeePolicy Leadkenix.leetheia.orgAnika SchaffterTraineeanika.schafftertheia.orgIA website hub page can be found here.information from ele

68、ctronic trading providersin the European equity markets,in order toimprove transparency and efficiency.Following discussions between the IA(particularly the IAs Equities TradingCommittee)and AFME,this document hasbeen updated to reflect the latestdevelopments in regulation and marketpractice.PRIVATE

69、 MARKETSAs investment in private assets has grown,private markets have become an increasinglyimportant part of the IAs work.In March the IApublished a Private Markets Policy Briefingexploring key trends in private markets inrecent years and the benefits of privatemarkets to both investors,and to the

70、 UK as itseeks to scale up companies and meet itseconomic,environmental,social andinfrastructure objectives.In our Policy Briefing,developed with the IAsPrivate Markets Committee,we note thatbarriers to private investment continue toThe discussion around Listing Rules reform isjust one part of a wid

71、er debate about thefactors and drivers impacting UK listings andthe wider capital markets competitiveness.The IA looks forward to working constructivelywith the FCA and indeed all key stakeholdersto ensure a vibrant,healthy UK listingsenvironment.ELECTRONIC TRADINGQUESTIONNAIREThe IA and the Associa

72、tion of FinancialMarkets in Europe(AFME)have jointlyupdated our Equities Electronic OrderHandling Questionnaire.The Questionnaire,first developed in 2016,provides a commonframework for buy-side clients to requestWe would like to see the existing regime forDCSS arrangements maintained for themost par

73、ts,but we suggest replacing thecurrent requirement for a sunset clause forenhanced voting rights with a requirementfor a review clause provision in DCSSarrangements at the point of IPO,mandating a continuation vote which couldbe triggered at a predetermined date.FURTHER INFORMATION:Hugo GordonSenior

74、 Policy Adviserhugo.gordontheia.orgKenix LeePolicy Leadkenix.leetheia.orgAnika SchaffterTraineeanika.schafftertheia.orgIA website hub page can be found here.exist,and set out key opportunities and asksidentified by the industry for opening upprivate assets investment and unlockingfurther capital to

75、invest in the UKs economyand infrastructure.These asks include:This Policy Briefing is part of the IAs widerplans for engagement with policy makers,market participants and key stakeholders aswe look to build a market that meets the UKsneeds.incentivising pension scheme investment ina wide range of p

76、rivate assetsimproving the infrastructure investmentpipeline through a stable policy frameworkand the development of a National IndustryStrategybroaden access to private marketsinvestment through innovation andevolution of the market,including:the development of fund structures thatremove barriers t

77、o investing in and holdingprivate assets,such as the Long Term AssetFund.the development of a regulatory andmarket framework that encouragesinnovations such as tokenisation.FURTHER INFORMATION:Hugo GordonSenior Policy Adviserhugo.gordontheia.orgKenix LeePolicy Leadkenix.leetheia.orgAnika SchaffterTr

78、aineeanika.schafftertheia.orgIA website hub page can be found here.Click here or press enter for the accessibility optimised versionINVESTMENTOPERATIONSINVESTMENTOPERATIONSCSDR SETTLEMENT DISCIPLINEUnder CSDR(Central Securities DepositaryRegime),the European Commission hadoriginally proposed two mec

79、hanisms:A cash penalty regime Which debited thefailing counterparty to a trade and creditedthose being failed into.Mandatory buy-in regime Forcing thefailing counterpart to purchase the stockwhen at fault to deliver to the entity failed into.Cash penalties went line in February 2022,with MBIs not ac

80、tioned.After much industrylobbying,the EU agreed to re-writemandatory buy-ins as a tooling of last resort,to only be introduced if settlement rates hadnot improved.Consequently,they taskedESMA with a review of the efficacy of the cashpenalty regime,and whether a recalibrationwas needed.In December 2

81、023,ESMA launched aconsultation on the technical mechanism ofthe CSDR cash penalty regime.In it,theydiscussed and proposed a number ofpotential changes,including progressivepenalties,a minimum value,assessment ofasset class categories and associatedpenalties and more.The IA engaged with members in r

82、espondingto the consultation.We argued againstmaking the mechanism more complex suchas progressive penalties and a minimumvalue,noting that already the operational costof processing cash penalties often exceedsthe value of cash penalties.We championedthe creation of a new ETF category,proposinga mec

83、hanism which pegged the cash penaltyrates against a funding benchmark such asthe ESTR.We noted the potential 600%increase in rates proposed by ESMA wouldlikely have a negative effect,with potentiallyincreased trading costs or lower liquidity.TheIA were aligned with much of the industry inits respons

84、e.FURTHER INFORMATION:Alex ChowInvestment Operations Policy Leadalex.chowtheia.orgIA Website Hub Page:CSDR,RegulatoryTrade and Transaction Reporting,In terms of next steps,ESMA expect to publisha final report by 30th September 2024.T+1 SETTLEMENTWork to support members with the transitionto T+1 sett

85、lement remains a key priority for theIA.Below we provide relevant updates perjurisdictions:North America The US will go live with atransition to T+1 Settlement by the 28th May2024,with Canada and Mexico transitioning onthe 27th May instead as they do not share theUS national holiday.In March 2023,th

86、e SEC published FAQs on thetransition.The FAQs include a re-iteration ontheir views around extended settlement(namely that it has not been modified from therules pre-transition,firms can leverageextended settlement but that it is intended foruse in unusual or limited circumstances).TheFAQs also prov

87、ide further colour on scope.The IA has been working with members toexplore the challenges and potential solutionsfor firms in addressing the change,includingon FX,fund settlement,the trade matchingon FX,fund settlement,the trade matchingprocess and more.UK On the 28th March,Charlie Geffen andHMT pub

88、lished the UK AcceleratedSettlement Taskforce report.The reportmakes several recommendations includingthat the UK should move no later than the endof 2027,should collaborate with the EU andexplore aligning transition if possible and thatmutual funds should move to T+2 toaccommodate.The taskforce is

89、nowsucceeded by a Technical Group,which willexplore and recommend changes necessaryto transition,as well as ultimately consider adate.The IA will be re-canvassing member viewson a potential UK transition and whetheralignment with Europe should be the soleposition,or whether we should recommendthe UK

90、 move ahead of time should the gap besufficiently big.The EU In late 2023 ESMA issued a Call forEvidence to gather stakeholder views on apotential EU transition to T+1 Settlement.TheIA responded outlining the challenges andpotential solutions and calling for alignmentwith the UK.In March 2024,ESMA p

91、ublished afeedback statement outlining initial responseviews on the T+1 move.Similarly on 25 January,the EuropeanCommission hosted a roundtable onshortening the settlement cycle in the EU,which included key industry stakeholderssuch as SEC Chair Gary Gensler and many firmCEOs.Whilst much of what was

92、 discussedwas not new,it did strike a more pro-transitiontone,with Commissioner Mairead McGuinnessdescribing T+1 in Europe as a case of“when,not if”.Whilst Europe havent explicitly mentioned apotential transition date,anecdotal discussionfrom industry suggests this could be 2028,though bullish and b

93、earish stakeholderssuggest this is too far or near respectively.Many stakeholders and associations arelooking to see how they can influence andadvocate for the EU and UK transition dates tomatch up.EMIR REFITEMIR Refit is a change to the existing EMIRtransaction reporting regime for derivativesand b

94、rings about an expansion of the numberof reportable fields from 129 to 204(203 forEurope),with a transition in April 2024 andSeptember 2024 for Europe and the UKrespectively.The IA is running working groups for bothdelegating and reporting members,to assistthem as they gear up towards the April 2024

95、and September 2024.Member feedbacksuggests that most firms expect to be readyby the April 2024 date for Europe,but thatthey expect a not insignificant list of issues tobe solved once live.Further memberfeedback indicates that some firms arelooking to transition towards a delegatingformat to help sol

96、ve for some of thecomplexity of the build.The IA has updated a draft reconciliation goodpractice ahead of go-live and is working withmembers on making sure this reflects industrypractice.Click here or press enter for the accessibility optimised versionThank you for readingInvestment&Capital MarketsQ1 2024 ReportInvestment&Capital markets webpage:www.theia.org/campaigns/investment-capital-marketsTo access the Members section of the InvestmentAssociation website,register here:www.theia.org/joining-the-investment-association/registerCookies 1 2 Terms 1 2 Privacy 1 2 P O W E R E D B Y