Brussels, 24 July 2020 | Europex welcomes the opportunity to take part in the present consultation. Below we provide our input to the Commission’s online questionnaire in an amended format to facilitate its publication on the Europex website.
Europex considers the following points, among others, to be of key importance:
- Charging the fees directly to Market Participants would the most efficient approach with RRMs collecting the fee as intermediaries. There would be significant risk of distortion of competition between different types of RRMs should the fee be charged directly to RRMs;
- The fee calculation must not discourage trading on regulated and transparent trading venues – thus orders should not be considered for the fee calculation, and a clear distinction should be made in the formula between standardised and non-standardised transactions;
- The proposed ex-ante approach for charging the fee would expose RRMs to an unacceptable financial risk – we therefore suggest ex-post calculation on a more regular basis (e.g. monthly or at least quarterly basis). Financial liability should lie with MPs in line with their overall responsibility for reporting.
Please see the full response attached.