Europex responds to ACER public consultation on REMIT – Functioning and Usefulness of the European Register of Market Participants

Brussels, 22 April 2016 | Europex welcomes the opportunity to respond to ACER’s public consultation on the “Functioning and Usefulness of the European Register of Market Participants” under REMIT. While we generally support the proposal put forward by ACER to improve the quality and utility of the CEREMP data, we would like to highlight a number of concerns in reaction to Question 5 and Question 12 of the present consultation. Please find the consultation response attached.
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Categories: Consultation Responses.

Europex response to ESMA consultation on Benchmark Regulation

Brussels, 31 March 2016 | In our response to the latest ESMA consultation on the Level 2 legislation for the EU Benchmark Regulation, Europex emphasises the need to consider commodity-specific aspects. Particularities of prices and data availability should be acknowledged when categorising commodity benchmarks. Europex further calls for a proportionate approach, leaving some flexibility to the administrators – where appropriate. Please find the whole response attached.
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Categories: Consultation Responses.

KIDs requirement under PRIIPs Regulation incompatible with wholesale energy trading

Brussels, 9 March 2016 | Given the latest draft of the Regulatory Technical Standards (RTS) on the layout of the Key Information Documents (KIDs) introduced by the Regulation on Packaged Retail and Insurance-Based Investment Products (PRIIPs Regulation), it seems that the scope may have been unintentionally changed and is now affecting also energy markets. With this position paper, Europex would like to express its concerns regarding this new development. While we support the Commission’s objective of improving the ability of retail investors to compare products and understand their features, we would like to highlight that the laid out requirements are
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Categories: Position Papers.

MiFIR/MAR: AII as an alternative to ISIN and the need to align the timing of the application of the ISIN obligation under MiFIR and MAR

Brussels, 4 March 2016 | ESMA’s current draft of the Regulatory Technical Standard (RTS) 231, inter alia specifying Article 3(1) of the Market in Financial Instrument Regulation (MiFIR), puts forward the obligation that each trading venue shall obtain an International Standards Organisation (ISO) 6166 International Securities Identification Number (ISIN) for each financial instrument. Europex does not agree with this obligation and calls for the reintroduction of Alternative Instrument Identifiers (AIIs) as a better adepted solution. In addition, Europex urges a postponement of the obligation to provide financial instrument reference data under MAR (Article 4) along with the corresponding requirement under
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Categories: Position Papers.

Call for evidence on overall financial markets reform: Europex contributes to DG FISMA consultation

Brussels, 29 January 2016 | Europex welcomes the Commission’s call for empirical evidence and concrete feedback on the EU’s overall regulatory framework for financial services. Reflecting the interests of exchange-based wholesale markets for electricity, gas and environmental products, the Europex response mainly focuses on the specificity of wholesale energy trading. Wholesale energy trading is in many ways different from traditional financial markets. Energy market participants use energy trading for mitigating their price risk along the value chain (sourcing, production, storage and retail-business). This is a common and important commercial practice and constitutes a necessary prerequisite for ensuring stable and affordable
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Categories: Consultation Responses.

Adjust the MiFID II/MiFIR implementation timeline to reality: Europex calls for a one-year delay for the application of MiFID II/MiFIR

Brussels, 25 November 2015 | MiFID II/MiFIR poses new and fundamental challenges to the business models of numerous stakeholders in the energy market. The presumed start of the application of MiFID II/MiFIR in January 2017 will require market participants, energy exchanges, clearing houses, regulators and many others to implement major changes in their general organisation and IT systems. All necessary modifications need to be anticipated, prepared for and implemented in due time and in full accordance with the new rules. However, the technical legislation (Level 2) that needs to provide guidance for the implementation of MiFID II/MiFIR has been significantly
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Categories: Press Releases.

Europex letter to DG FISMA on concerns on MiFID II position limits regime

Brussels, 11 December 2015 | In a letter to Mr Martin Merlin, Director at DG Fisma, Europex express its serious concerns about the Level 2 rules for the position limits regime under MiFID II as proposed by ESMA as part of the Regulatory Technical Standards (RTS) that were published on 28 September 2015. Europex calls for a change in the timing of the beginning of the application of spot month limits and the use of open interest as a basis for other months limits in the RTS 21. Please find the letter to Mr Merlin attached.
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Categories: Position Papers.