Association Française des Professionnels des Titres (« France Post-Marché « ) is the French association representing the post- trade industry. All 100 members of France Post-Marché are players in the securities market and back office functions: banks, investment firms, FMIs etc., acting in France and more generally in Europe.
The French Banking Federation (FBF) represents the interests of the banking industry in France. Its membership is composed of all credit institutions authorised as banks and doing business in France, i.e. more than 390 commercial, cooperative and mutual banks. They employ 373,000 people in France and around the world, and serve 48 million customers.
France Post-Marché and FBF welcome the CPSS/IOSCO consultation on the guidance report for FMIs recovery plans. Various regulations in most parts of the world and in Europe in particular are reinforcing the role and use of infrastructures in financial markets as a mean to reduce systemic risk globally. It is hence essential that these infrastructures are adequately regulated to limit their likelihood of default but also that recovery and resolution regimes are properly defined to ensure the continuity of services in case of default.
We believe that developing proportionate recovery and resolution plans is one of the key challenges to prevent crises by setting harmonised mechanisms at global level that may mitigate systemic risks, thereby contributing to financial stability and sustained economic growth.
As the voice of the French banks and post-trade market players, we would like to make comments on key aspects of the guidance report and give recommendations, on the one hand, from the perspective of users and participants to FMIs, and on the other hand, from the FMIs‘ viewpoint, since Euroclear France and L.C.H Clearnet SA are France Post-Marché members .
Please find below a summary of our comments, our detailed contribution. In addition, some track changes to the guidance report will be sent to you in the coming days.
