ALFI responds to the EU Commission on the CSDR Refit proposal
27 May 2022
Regarding cash penalties and for Tier 2 asset managers, we observed that the cost of the monitoring outweighs the penalties received. We urge the Commission and ESMA to streamline the corresponding treatment.
The aim of the consultation for the Commission was to collect
feedback in particular on the two following measures to improve the
Settlement Discipline Regime. Firstly, mandatory buy-ins would be
applicable to certain financial instruments or categories of
transactions. Secondly, a pass-on mechanism would prevent a cascade of
failed settlements.
We are happy to contemplate a revisited settlement discipline framework.
Regarding the buy-in implementation, we are still of the view that this route should only be optional and not mandatory....
View the ALFI response
ALFI
© ALFI - Association of the Luxembourg Fund Industry
