1、Click here or press enter for the accessibility optimised versionINVESTMENT&CAPITAL MARKETSQ4 2023Click here or press enter for the accessibility optimised versionCONTENTSCONTENTSFOREWORDSUSTAINABILITY AND RESPONSIBLE INVESTMENTCAPITAL MARKETSINVESTMENT OPERATIONSSDR and Investment Labels Final Rule

2、sEU SFDR Review and IA Plans to RespondOngoing Work on ESG Data and Ratings ProvidersUK Transition Plan TaskforceSupporting the Real Economy TransitionUN Climate Change ConferenceCMA Final Guidance on Environmental CooperationInvestment Research ReviewDevelopment of Consolidated TapesFCA:Review of C

3、ompetition Concerns in WholesaleNew Public Offers and Admissions to Trading RegimeA Review of the UK Transparency Regime for non-equityInstrumentsPrivate MarketsT+1 Accelerated SettlementEMIRClick here or press enter for the accessibility optimised versionFOREWORDFrom Galina DimitrovaFOREWORDWelcome

4、 to the IAs Investment&CapitalMarkets policy report for the last quarter of2023.With this report we bring together theIAs important investment and capital marketsactivity over the past few months.On the Sustainability and ResponsibleInvestment front,the IA has been preparingfor the publication of th

5、e final rules on newSDR(“Sustainability Disclosure Requirements”)and investment labels regime,whilst alsoresponding to the European Commissionsreview of the Sustainable Finance DisclosureRegulation.The IA has also continued itssupport for the Net Zero transition process,working with the UKs Transiti

6、on PlanTaskforce as it developed its DisclosureFramework and attending the UNs COP 28Climate Change Conference in Dubai.It has also been a busy period in the capitalmarkets space.The IA is leading efforts toprepare UK investment management industryfor the upcoming transition to T+1 settlementin Nort

7、h America,while also representing ourmembers on the UK Accelerated SettlementTaskforce and wider industry discussions inEurope.We also continue to engage with keyindustry stakeholders,as well as policymakers and regulators,on significant topicssuch as the UK Investment Research Review,the developmen

8、t of a UK and EUconsolidated tape,and reviews of theprospectus regime and the transparencyregime for non-equity instruments.Further details on these and many otheraspects of our work are covered in this report.We hope you continue to find this policyreport a useful resource and please do nothesitate

9、 to get in touch if you have anyquestions or feedback.We would also like to take this opportunity towish our members a wonderful festiveseason,a restful holiday break and a veryHappy New Year.We look forward to workingwith you all again in 2024 and to continue tosupport you with the issues that matt

10、er themost!GALINA DIMITROVADIRECTOR,INVESTMENT ANDCAPITAL MARKETSThe Investment and Capital Markets hubpage can be found here.Click here or press enter for the accessibility optimised versionSUSTAINABILITYAND RESPONSIBLEINVESTMENTSUSTAINABILITYANDRESPONSIBLEINVESTMENTSDR AND INVESTMENT LABELS FINALR

11、ULESOn 28th November,the FCA published its finalrules on Sustainable Disclosure Requirements(SDR)and investment labels.The SDR finalrules introduce a package of measures tohelp consumers navigate the market ofsustainable investment products.Thesemeasures include:Labels for sustainability funds under

12、 thefollowing headings:Sustainability Improvers;Sustainability Focus;Sustainability Impact;Sustainability Mixed Goals.Naming and marketing rules for funds witha label or funds using sustainability-relatedterms in their naming and marketing.The IA is supporting members with theimplementation of these

13、 rules via a number ofchannels:An anti-greenwashing rule for all FCA-authorised firms,clarifying existing FCArules that(sustainability)claims should beclear,fair and not misleading.Disclosures at several different levels:consumer facing disclosure;detailedproduct level disclosure;and entity-leveldis

14、closure.Requirements for distributors to ensure thatproduct-level information is made availableto consumers.The IA held a joint webinar with the FCA onthe final rules on 11th December.The IA has established an SDRImplementation Forum a discussion groupwhere members can discuss experiences,challenges

15、 and best practice related to SDRimplementation.First meeting to take placein early January 2024.The IA,in partnership with EvershedsSutherland,is developing industry guidanceto help members implement the final rules.FURTHER INFORMATION:Flora TudhopePolicy Lead,Sustainability&ResponsibleInvestmentfl

16、ora.tudhopetheia.orgIA website hub page can be found here.EU SFDR REVIEW AND IA PLANS TORESPONDThe European Commission published itsexpected consultation on the implementationof the Sustainable Finance DisclosureRegulation(SFDR)in September.Theconsultation covers key areas such as currentrequirement

17、s of SFDR,including disclosure ofprincipal adverse impacts(PAIs);the cost ofdisclosures under the SFDR today;and thequality of data and estimates.Theconsultation also covers interaction with othersustainable finance legislation and potentialchanges toThe IA has set up an informal forum withother rel

18、evant trade bodies to see wheresynergies can be made.Further consumer testing will beundertaken on the sustainable fund labelsto help members with further guidance onhow to communicate the labels effectivelyto end investors.The IA is updating its training offering formembers on sustainability relate

19、d topics,including on SDR.SDR will be a key discussion topic at the IASustainability Conference on 25 April 2024.the disclosure requirements for financialmarket participants at both entity and productlevel.Contrary to the current regime,theconsultation suggests potentialestablishment of a categorisa

20、tion system forfinancial products,similar to the approachbeing considered by the FCA in its SustainableDisclosure Requirements(SDR)regime.Following extensive member engagement,the IA submitted a response on 15 December.While many aspects of SFDR are flawed,it isclear there is little appetite for a w

21、ide scaleoverhaul of SFDR.There is a preference to fixelements of SFDR than start from scratch,inparticular,due to the need for consistency inthe information given to end investors ratherthan constant change.Key IA views include:Entity level reports:we do not believe thatthe disclosure of mandatory

22、and opt-inPrinciple Adverse Impact(PAI)indicators atentity-level is useful and therefore,shouldbe removed from future iteration of SFDR.FURTHER INFORMATION:Carol ThomasHead of Sustainability&ResponsibleInvestmentcarol.thomastheia.orgFlora TudhopePolicy Lead,Sustainability&ResponsibleInvestmentflora.

23、tudhopetheia.orgIA website hub page can be found here.Product level disclosure:we do not want tosee uniform disclosure requirements for allfinancial products offered in the EU overand above existing requirements,regardlessof a funds sustainability-related claims orany other considerations.We do nots

24、upport having product-level disclosuresexpressed on a scale as it would beextremely challenging to determine whichobjective information should be expressedon a scale given the wide array of ESGissues and the subjective nature of theseissues.While the consultation doesnt ask aboutscope,IA members are

25、 calling forsegregated mandates to be out of scope ofthe next iteration of SFDR.Product categorization:members broadlysupport Approach 1 which is to splitcategories according the to the type ofinvestment strategy of the product,similarto the FCA SDR approach.Whilst industryrecognizes a lot of work h

26、as gone in toimplementing Article 8 and 9,there is nosupport for a product categorization alongApproach 2 which would be to convertArticles 8 and 9 into formal productcategories.Three of the proposed categories aresimilar to FCA SDR Sustainability Focus,Improver and Impact.However,theCommission is p

27、roposing a fourth label,Category C,focused on exclusions.There islarge support for this category fromourmembers,in an EU voluntarycategorisation regime,provided they are notmandatory exclusions.This should becoupled with clear minimum criteria toensure that exclusions alone are meaningfulas a sustai

28、nable approach.Exclusionaryfunds provide important benefits toinvestors seeking to both(1)mitigate theirESG risk or express their preferences,and(2)benefit from the long-term returnsgenerated by high-quality,low-costinvesting in passively managed,broadlydiversified,index funds.In terms of the labels

29、 being mutuallyexclusive,while members support fundsonly have one label/category,the ESGstrategies/tools/underlying funds that aproduct may employ to achieve its intentionshould not be mutually exclusive.FURTHER INFORMATION:Carol ThomasHead of Sustainability&ResponsibleInvestmentcarol.thomastheia.or

30、gFlora TudhopePolicy Lead,Sustainability&ResponsibleInvestmentflora.tudhopetheia.orgIA website hub page can be found here.MiFID 2:regarding to what extent shouldsustainability preferences under MiFID IIand IDD refer to those possiblesustainability product categories-the waysustainability preference

31、have been definedin MiFID clearly does not align directly toArticle 8 and 9 funds and has proved quitedifficult for firms to interpret.We do notwant an approach that prevents clients frominvesting in,for example,ESG risk-managedstrategies,if they are in fact the rightstrategies for their preferred i

32、nvestmentoutcomes(i.e.strategies without a dualobjective).Ideally,“sustainabilitypreferences”should allow for strategiescovering the full breadth of possibleinvestment outcomes that investors may betargeting in line with their particularsustainability needs and suitabilitypreferences process should

33、allow investorsto be matched with the right strategies forthem.ONGOING WORK ON ESG DATA ANDRATINGS PROVIDERSUK ESG Data and Ratings Code of ConductA year in the making,the finalised UK Code ofConduct for ESG Data and RatingsProviderswas published on 14 December andICMA has agreed to take ownership o

34、f theCode going forward.The IA has been amember of the industry working group thathelped to develop the Code.In line withIOSCOs recommendations,the Code isstructured around four key outcomes:Naming and marketing rules:similar to theviews we gave to the FCA for SDR,anyprohibition on product names and

35、marketing materials by restricting the use ofESG-related terms to products adhering tothe categorisation regime could bedisproportionate to the harms EU regulatorsare trying to mitigate/avoid.FURTHER INFORMATION:Carol ThomasHead of Sustainability&ResponsibleInvestmentcarol.thomastheia.orgFlora Tudho

36、pePolicy Lead,Sustainability&ResponsibleInvestmentflora.tudhopetheia.orgIA website hub page can be found here.1.Good Governance:ESG ratings and dataproducts providers are expected to ensureappropriate governance arrangements arein place that enable them to promote anduphold the Principles and overal

37、lobjectives of the code.2.Systems and Controls:ESG ratings anddata products providers are expected toadopt and implement written policies andprocedures designed to help ensure theissuance of high quality ESG ratings anddata products.3.Management of Conflicts of Interest:ESGratings and data products

38、providers areexpected to identify,avoid or appropriatelymanage,mitigate and disclose actual orpotential conflicts of interest that maycompromise the independence andobjectivity of ESG ratings and dataproducts providers operations.4.Transparency:ESG ratings and dataproducts providers are expected to

39、makeadequate levels of public disclosure andtransparency a priority for their ESG ratingsand data products.This includes theirmethodologies and processes to enable usersto understand the product and any associatedpotential conflicts of interest,whilemaintaining a balance with respect toproprietary o

40、r confidential information,dataand methodologies.To try and ensure global interoperability andcoherence,the meetings through out the yearhave been attended virtually by observersfrom different jurisdictions,including theMonetary Authority of Singapore(MAS),theJapanese Financial Services Agency(JFSA)

41、and the Ontario Securities Commission(OSC),and the U.S.Securities and ExchangeCommission(SEC).In the absence of a UKregulatory framework for ESG data and ratingsproviders,we see the Code providing theabove key outcomes until such time as thereis a regulatory framework in the UK for thoseproviders.FU

42、RTHER INFORMATION:Carol ThomasHead of Sustainability&ResponsibleInvestmentcarol.thomastheia.orgPaul ScapingPublic Policy Specialistpaul.scapingtheia.orgIA website hub page can be found here.EU regulatory frameworks for ESG RatingsProvidersThe European Commission published aproposal for an ESG Rating

43、s Regulation inJune 2023 and the IA submitted a response tothe draft proposals to the Commission in earlySeptember with our key views on theproposals.Development of the proposals arecontinuing at pace in the EU.Key pointsinclude whether to increase the scope bothESG ratings and data providers(as cur

44、rentscope only covers ESG ratings providers).Proposals also include how the ESMAsupervisory framework should framed,obligations for independence and conflicts ofinterest and principles on integrity andreliability.The treatment of investmentmanagers internal ratings is also a key focusfor the IA.It i

45、s likely that the EU legislativeprocess will aim to finalise this file in Q1 2024ahead of the EU elections next year and thecurrent colleague of Commissioners changenext year as well.UK TRANSITION PLAN TASKFORCEThe IA continues to work as a member of theTransition Plan Taskforce(TPT)through itsdeliv

46、ery group and as a member of a workinggroup producing sector guidance forinvestment manager transition plans.The TPT published the final version of itsDisclosure Framework in October,following aperiod of consultation.The TPT wasestablished by the UK Government in 2022 todevelop guidance on a gold st

47、andard forprivate sector climate transition plans.TheFCA(which participated in TPT)isencouraging firms to“engage early”with theframework,which it says,“provides a set ofgood practice recommendations to helpcompanies across the economy make highquality,consistent and comparable transitionplan disclos

48、ures”.The regulator has confirmedits previous commitment to“draw on”the TPTframework as it develops disclosureexpectations for listed companies,investmentmanagers and FCA-regulated asset owners.FURTHER INFORMATION:Paul ScapingPublic Policy Specialistpaul.scapingtheia.orgIA website hub page can be fo

49、und here.The working group producing sectorguidance for investment managers,is nowdrawing to a close with the document out formarket consultation.In December,the IAhosted a webinar with the TPT to buildawareness of the guidance.The TPTs currentmandate ends in February 2024,and the IAwill continue to

50、 work with policymakers toensure the appropriate policy environment isbuild around the use of transition plans in theUK.SUPPORTING THE REAL ECONOMYTRANSITIONWe continue to support IA members in theircommitments to help achieve a net zero-aligned and nature positive economy throughpolicy advocacy,inc

51、luding that undertakenindirectly by their trade associations.In the last quarter,our engagement withpolicymakers has included developingunderstanding of the role of natural capital,and emphasising the importance of a clearpolicy underpinning for the green transition.Inan informal coalition with orga

52、nisationsincluding WWF,E3G,UK Finance and the CBI,the IA has argued for the Government to domore to set out its plans to achieve low-carbon investment,including tracking financialflows towards the UKs transition priorities.Wehave held meetings with ministers and officialsin support of this objective

53、.Most recently,the UK ParliamentEnvironmental Audit Committee supported acentral element of this call in the report of itsinquiry on the financial sector and the UKs netzero transition,when it recommended anindependent body to be tasked with trackingclimate-and nature-related financial flows,aswell

54、as investment in high-carbon projects.The IA has been engaging with this inquirysince it was launched in 2022.Most recently,we responded to the UKGovernment Department for Energy Securityand Net Zeros call for evidence on the valueof incorporating scope 3 emission reporting inthe UKs sustainability

55、disclosurerequirements.We will also continue to engagewith policymakers responsible for the UKsTransition Finance Market as it launches underthe recently announced chair,VanessaHavard-Williams,in early 2024.FURTHER INFORMATION:Carol ThomasHead of Sustainability&ResponsibleInvestmentcarol.thomastheia

56、.orgFlora TudhopePolicy Lead,Sustainability&ResponsibleInvestmentflora.tudhopetheia.orgPaul ScapingPublic Policy Specialistpaul.scapingtheia.orgUN CLIMATE CHANGE CONFERENCEIn December,the IA attended the UN climatechange in Dubai where we were confirmed asofficial observers during the opening plenar

57、ymeeting.Organisations must be admitted asobservers to the UN climate changeconference to send representatives to attendits main annual meeting,known as COP.Observers are also able to formally participatein consultative processes throughout the yearbuilding to the next COP.The IA will now be working

58、 with its ClimateChange Working Group and Sustainability andResponsible Investment Committee to furtheridentify the issues on which it will be a priorityfor the IA to engage.The UN conference andassociated initiatives consider issues includingcarbon markets,the integrity of businessclimate commitmen

59、ts,energy policy,and theprovision of private and public funding formitigation,adaptation and repairing loss.We will also spend time in 2024 developingrelationships with the policymakers from UKGovernment and international bodies whoparticipate in the climate conference.InDubai,we were pleased to org

60、anise with ICI Global aroundtable for members with RodrigoBuenaventura(Chair of the IOSCO SustainableFinance Task Force),Martin Moloney(IOSCOSecretary General)and Emmanuel Faber(ISSBChair).CMA FINAL GUIDANCE ONENVIRONMENTAL CO-OPERATIONIn October,the Competition and MarketsAuthority(CMA)published it

61、s final guidanceon environmental sustainability agreements.The Guidance recognises that initiatives whichexist to provide a common framework to helpbusinesses set and disclose environmentaltargets(including those which allow for theunilateral setting,disclosure and reporting ofparticipants targets)a

62、re unlikely to have anappreciable adverse effect on competition.The competition regulator consulted on draftguidance earlier this year and the finalguidance reflects several elements of the IAsfeedback.A new section of the Guidance not included in the previous draft coversagreements between sharehol

63、ders onFURTHER INFORMATION:Carol ThomasHead of Sustainability&ResponsibleInvestmentcarol.thomastheia.orgFlora TudhopePolicy Lead,Sustainability&ResponsibleInvestmentflora.tudhopetheia.orgPaul ScapingPublic Policy Specialistpaul.scapingtheia.orgpromoting corporate policies that pursueenvironmental su

64、stainability.It states that anagreement between shareholders to vote orlobby jointly for corporate policies thatsupport environmental sustainabilityobjectives will be unlikely to infringecompetition law.The Guidance has also beenupdated to state that a trade associationproviding legitimate assistanc

65、e,facilitation orsupport to firms taking part in anenvironmental sustainability agreement isunlikely to raise competition concerns.While members are advised to familiarisethemselves with this Guidance,the CMA willoperate an open-door policy for informalguidance on sustainability agreements wherether

66、e is uncertainty on the application of theGuidance.The FCA has also welcomed theguidance and committed to having regard tothe CMAs approach when exercising its owncompetition powers.This clarification of howthe two regulators would exercise their dutieswas requested by the IA.FURTHER INFORMATION:Car

67、ol ThomasHead of Sustainability&ResponsibleInvestmentcarol.thomastheia.orgFlora TudhopePolicy Lead,Sustainability&ResponsibleInvestmentflora.tudhopetheia.orgIA website hub page can be found here.Click here or press enter for the accessibility optimised versionCAPITAL MARKETSCAPITALMARKETSINVESTMENT

68、RESEARCH REVIEWIn July,Rachel Kent published the UKinvestment Research Review which exploredthe investment research environment in theUK and looked to identify and address anyissues relating to coverage and scope,particularly of small-to-mid-cap companies,as part of the wider discussion about how to

69、attract and retain growth companies in theUK.The report made the followingrecommendations:Introduce a Research Platform to helpgenerate research.Allow additional optionality for paying forinvestment research.Allow greater access to investmentresearch for retail investors.Involvement of academic inst

70、itutions andbursaries in the provision of investmentresearch.The IA continues to engage regularly withmembers,the Investment Research Reviewteam and other key stakeholders as they takethis work forward.The IA has produced aposition paper setting out that the IA issupportive in principal of optional

71、rebundling,as well as key aspects of the framework whichwould be needed to make optionalrebundling research payments viable,and hasbeen socialising this position withstakeholders.DEVELOPMENT OF CONSOLIDATEDTAPESThe IA submitted its response to FCAconsultation paper(CP)23/15 The Frameworkfor a UK Con

72、solidated Tape in September.Whilst this CP focused on developing a CT forbonds,there were many overarching themeswithin the CP which will also be relevant to aCT developed for equities and ETFs.The CPSupport issuer-sponsored research byimplementing a Code of Conduct.Clarify aspects of the UK regulat

73、ory regimefor investment research and considerintroducing a bespoke regime.Review the rules relating to investmentresearch in the context of IPOs.FURTHER INFORMATION:Hugo GordonSenior Policy Adviserhugo.gordontheia.orgAnika SchaffterTraineeanika.schafftertheia.orgIA website hub page can be found her

74、e.also included a Discussion Chapter with anumber of targeted questions relating todeveloping a CT for the UK Equity/ETFmarket in which members of this CP activelyfed into.The IA is now awaiting the FCAs upcomingpublication of a Policy Statement setting outthe proposed framework for a consolidatedta

75、pe for fixed income and continues to pushfor a CT for equities/ETFs.FCA:REVIEW OF COMPETITIONCONCERNS IN WHOLESALE MARKETDATAAt the end of August,the FCA published anUpdate Report on their Wholesale DataMarket Study.This study is a part of theirwider work on wholesale data which includeda trades dat

76、a review and the proposals tointroduce a consolidated tape in the UK.Atthe time the IA expressed strong concernsabout competition issues in wholesale datamarkets,including high costs,a lack oftransparency and restrictive licensingconditions.Based on the responses received to theirstudy the FCA has i

77、dentified the followingemerging themes and issues:BenchmarksCredit ratings dataThey estimate that majority of aggregateUK revenues in the market is accounted forby three larger providers.Analysis shows concentrated markets andlimited switching by benchmark users.This market power may enable somebenc

78、hmark administrators to imposecommercial practices resulting in highercosts for benchmark users and furtherweaken competitive pressures.92%of revenue from UK credit ratingagency are from the Big Three credit ratingagencies(CRA)despite a number of smallerfirms entering and expanding into themarket.FU

79、RTHER INFORMATION:Hugo GordonSenior Policy Adviserhugo.gordontheia.orgIA website hub page can be found here.Market Data Vendors servicesWhile CRAs are required to publish data forfree under UK law,this varies acrossjurisdictions and many data users do notutilise free data sources due to theperceived

80、 quality of data,cost of acquiringmanually and uncertainty about the termsof use due to lack of licence agreement.In response to the survey,data usersemphasized a lack of transparency onprices for credit ratings data,with concernsthis has led to price discrimination andlimited competition.There are

81、a small number of larger MDVsfollowed by a long tail of smallerspecialised providers.There have been nomajor entrants in the markets and exit hasmainly occurred due to M&A.However,it isevident that existing firms are entering newmarket segment with new services andproducts.Most buyers are sophistica

82、ted users,however the majority of demand-siderespondents reported they have little or nobargaining power when negotiating with thelargest vendors.The IA responded to the Update Report,reiterating the concerns previously raised bythe industry and stating that we welcomefurther exploration and analysi

83、s of the issuesraised and await the final report in early 2024.The FCA will issue a final report by March ofnext year,in which they make a final decisionas to whether to refer to the CMA,takealternative actions,or take no action.NEW PUBLIC OFFERS ANDADMISSIONS TO TRADING REGIMEAs part of its wider w

84、ork on increasing thecompetitiveness and attractiveness of the UKListings environment,the FCA over thesummer published a series of engagementpapers relating to their development of a newPublic Offers and Admissions to TradingRegime as they looked to takeforward previous proposals recommended bythe W

85、holesale Markets Review andProspectus Review.These papers focused on:Well-established and large MDVs holdmarket power resulting from switchingcosts and other frictions in the switchingprocess.FURTHER INFORMATION:Hugo GordonSenior Policy Adviserhugo.gordontheia.orgAnika SchaffterTraineeanika.schaffte

86、rtheia.orgIA website hub page can be found here.The IA submitted a response in which we setout views on prospectus requirements.HM Treasury also recently published aStatutory Instrument setting out theframework for the new UK prospectus regime,including:This however will not come into force until th

87、eFCA has had further time to opine on specificrules.A REVIEW OF THE UK TRANSPARENCYREGIME FOR NON-EQUITYINSTRUMENTSThe FCA are expected to publish their longCreating a general prohibition on publicoffers of securities,followed by a series ofexceptions from this prohibition.Establishing a new regime

88、for securitiesadmitted to trading on a regulated marketor multilateral trading facility.Creating a new regulated activity ofoperating an electronic system for publicoffers of certain securities.These papers form an initial stage in thedevelopment of specific rules proposals onwhich the FCA plan to c

89、onsult next year.Whether or how to set prospectusrequirements for companies seekingadmission of theirsecurities to trading on regulated markets;Whether or not to set prospectusrequirements on issuers raising furthercapital on UK regulatedmarkets;How issuers may include forward-lookinginformation in

90、prospectuses;Prospectus requirements for non-equitysecurities;How to approach setting prospectusrequirements for issuers seeking to admitsecurities to juniormarkets;andWhat rules should be set for firms thatchoose to operate a public offer platform toallowcompanies to raise capital from investorswit

91、hout being admitted to a public market.FURTHER INFORMATION:Hugo GordonSenior Policy Adviserhugo.gordontheia.orgAnika SchaffterTraineeanika.schafftertheia.orgIA website hub page can be found here.centre of proposals to inject growth into theeconomy and which in particular looks toincrease the allocat

92、ion of assets undermanagement into unlisted equities.The IA Private Markets Committee is currentlyin the process of finalising an educationaldocument which builds on previous piecespulled together by the IA as part of ourengagement work with policy makers,regulators and other key stakeholders.In the

93、new document we will look to set out keyasks for policy makers and other stakeholdersin order to drive positive structural changeswithin the market,including:Unlocking of pension capital;Driving infrastructure and Net Zeroinvestment;The development of new structures(andexpansion of existing ones suc

94、h as theLong-Term Asset Fund)in order to unlockinvestment in unlisted and illiquid assets.awaited consultation on the review of thetransparency regime for non-equityinstruments on 19 December.A major focus ofthis consultation is expected to be an overhaulof the current deferrals regime for bonds.Ahe

95、ad of this publication the IAs DeferralsWorking Group has met with the FCA todiscuss what the buyside considers to be anoptimal deferrals regime for both volume andprice.To date IA members have suggesedthatthe FCA consider a two-week deferralperiod for both price and volume would be ofbenefit in mos

96、t instances.We understand thatfor some block trades a four-week deferralperiod is needed and in such instances detailsshould be published on an aggregate basis.The IA continues to engage with both the FCAand the sell-side on this topic.PRIVATE MARKETSRecent discussion at the Private MarketsCommittee

97、 have focused heavily on the JulyMansion House speech,which places theinvestment management industry front andFURTHER INFORMATION:Hugo GordonSenior Policy Adviserhugo.gordontheia.orgIA website hub page can be found here.Click here or press enter for the accessibility optimised versionINVESTMENTOPERA

98、TIONSINVESTMENTOPERATIONST+1 ACCELERATED SETTLEMENTT+1 Settlement refers to recent marketinitiatives aimed at amending current capitalmarkets settlement cycles.The cycle iscurrently at T+2 in most major markets withpolicy makers looking to accelerate this toT+1.In the UK and Europe,conversations aro

99、undT+1 settlement continue at a pace,and the IAis active participation on the UK AcceleratedSettlement Taskforce.The IA is supportive in principle of a move toT+1,but there are particular challengesrelating to the following areas.Trade matchingFX liquidity availabilityFX settlement-Payment vs Paymen

100、tnetting tool availabilityThe IA has created a detailed T+1 overview,detailing how current processes are impactedand on what firms are doing to address them.We are working with members on UK T+1advocacy,indicating preferring alignment withthe EU,if possible,but noting differing viewson what should h

101、appen should provisional UKand EU dates be too far apart.The IA also continues to engage with keymarket stakeholders such as CLS and DTCC,and has communicated regularly withmembers through working groups andsurveys,keeping them updated on key marketupdates and allowing firms to benchmarktheir positi

102、on.Next steps for the IA:Funding and cashflow managementThe impact on ETFs(Exchange TradedFunds)Inventory ManagementSecurities LendingContinued member engagement in thelead-up to the May 2024 transition date forNorth America.FURTHER INFORMATION:Alex ChowInvestment Operations Policy Leadalex.chowthei

103、a.orgIA Website Hub Page:CSDR,RegulatoryTrade and Transaction Reporting,EMIREMIR 3.0The IA continues to engage,via EFAMA,onthe EMIR 3.0 proposals to update theEuropean Market Infrastructure Regulation(EMIR).The proposals seek to strengthen thesupervisory framework of the EU clearingecosystem and inc

104、rease the attractiveness ofEU counterparties(CCPs).The IA has particular concerns regardingproposals to introduce an Active AccountRequirement,which would require EU marketparticipants to clear a proportion of theirtransactions in certain derivatives at activeaccounts at EU CCPs.While the EU views t

105、heproposals as countering risks to EU financialEngagement with the SEC on challengesaround FX PvP netting and extendedsettlement.Collaboration with the UK AcceleratedSettlement Taskforce and members toestablish a UKposition and roadmap to T+1 Settlement.Responding to the ESMA call for evidencedue 15

106、 December.stability by reducing concentration of clearingat some third-country CCPs,the IA alongwith several other industry bodies includingEFAMA,AIMA,ISDA and the FIA finds thatthese proposals could be harmful to thecompetitiveness of the EU,would increasecosts and could potentially hamper ourmembe

107、rs ability to provide best execution toclients.The IA is therefore supporting EFAMA in itsadvocacy in Europe on this issue as theindustry looks to seek a compromise solution,including an initial requirement for anoperational account only,with any furtherintroduction of requirements to be introducedo

108、nly after further cost-benefit analysis.EMIR RefitEMIR Refit is a change to the existing EMIRtransaction reporting regime for derivativesand brings 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

109、 UKrespectively.Our members approach to EMIR is split,withsome members conducting reporting onbehalf of their funds and clients,and somemember firms opting to delegate reporting tothe brokers whilst monitoring whats beingreported.Amongst the issues include datasourcing for some of the particular fie

110、lds,interaction and engagement with brokers andclients and ambiguous wording around someof the requirements.The IA is working withother sell-side trade bodies,the regulatorsand members to establish best practice as itcomes to some of these initiatives.The IA is running working groups for bothdelegat

111、ing and reporting members,to assistthem as they gear up towards the April 2024and September 2024.Click here or press enter for the accessibility optimised versionThank you for readingInvestment&Capital MarketsQ4 2023 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