Working in collaboration with AFME, AFTI, AGC, AIMA, AMAFI, Assogestioni, ASSOSIM, BVI, DACSI, EBF, EDMA Europe, ICMA and the IA, ISLA submitted yesterday a letter to the European Commission (EC) and the European Securities and Markets Authority (ESMA) regarding the implementation of the CSDR Settlement Discipline Regime to improve efficiency and safety in European capital markets.
The joint letter references the extensive consultation process and market engagement exercise that was undertaken prior to the implementation of MiFID, and asks for the authorities to adopt a similar approach. Key areas of focus include the timing around the introduction of cash penalties, the deferral of the mandatory buy-in regime, and the implementation of monitoring processes.
The full letter may be found here