EU Regulatory Update
European Commission Adopts Measures Regarding European Financial Supervision for the Capital Markets Union
On 20 September, the European Commission proposed a series of measures to “reform the EU’s supervisory architecture” and create “stronger and more integrated European financial supervision for the Capital Markets Union.” As the press release explains, the measures aim to: (i) strengthen EU supervisory coordination; (ii) extend direct capital markets supervision by ESMA; (iii) improve the governance and funding of European Supervisory Authorities (“ESAs”); and (iv) “promot[e] sustainable finance and FinTech.”
- Create Stronger Coordination of Supervision Across the EU: The measures would: (i) authorize the ESAs to set “EU-wide supervisory priorities” and “check the consistency of the work programmes of individual supervisory authorities with EU priorities and review their implementation”; (ii) give EIOPA a “stronger role in promoting convergence in the validation of the internal models that some large insurance companies use to calculate requirements on solvency capital”; and (iii) increase the efficiency of the European Systemic Risk Board “in order to strengthen its oversight of risks for the financial system as a whole.”
- Extend Direct Capital Markets Supervision by ESMA: The measures would “make ESMA the direct supervisor over certain sectors of capital markets across the EU” and grant it the authority to: (i) “authorise and supervise the EU's critical benchmarks and endorse non-EU benchmarks for use in the EU”; (ii) “approv[e] certain EU prospectuses and all non-EU prospectuses drawn up under EU rules”; (iii) “authorise and supervise certain investment funds with an EU label with the aim of creating a genuine single market for these funds”; and (iv) have a “greater role in coordinating market abuse investigations.”
- Improve Governance and Funding of the ESAs: The measures would: (i) allow ESAs to make “decisions more independently from national interests”; (ii) allow “interested parties . . . to ask the Commission to intervene if the majority consider that the ESAs have exceeded their competencies when issuing guidelines or recommendations”; and (iii) “make the funding of the ESAs independent from national supervisors.”
- Promote Sustainable Finance and FinTech: The measures would require that: (i) ESAs “promote sustainable finance, while ensuring financial stability”; (ii) “take account of environmental, social and governance-related factors and risks in all the tasks they perform”; and (iii) “prioritise FinTech and . . . coordinate national initiatives to promote innovation and strengthen cybersecurity.”
To achieve these goals, the European Commission published and is seeking feedback with regards to:
- A communication to the European Parliament, the Council, the European Central Bank, the European Economic and Social Committee, and the Committee of the Regions on “reinforcing integrated supervision to strengthen Capital Markets Union and financial integration in a changing environment”;
- A proposal for a regulation amending regulations related to the EBA, EIOPA, ESMA, European venture capital funds, European social entrepreneurship funds, MiFIR, long-term investment funds, financial benchmarks, and securities prospectuses;
- A proposal for a regulation amending Regulation (EU) 1092/2010 establishing the ESRB;
- A proposal for a directive amending MiFID II and Solvency II; and
- An amendment of a pending proposal for a regulation amending (i) Regulation (EU) 1095/2010, regarding ESMA; and (ii) Regulation (EU) No 648/2012, regarding “the procedures and authorities involved for the authorisation of CCPs and requirements for the recognition of third-country CCPs” (the “EMIR II Commission's proposal”).
Two fact sheets, available here and here, were published regarding the proposed measures. The consultation period for the legislative proposals closes on 17 November 2017. The proposals will now be discussed by the European Parliament and the Council.
ESAs Publish Report on Risks and Vulnerabilities in the EU Financial System
On 21 September, the Joint Committee of the European Supervisory Authorities (EIOPA, EBA, and ESMA) published its autumn 2017 report on risks and vulnerabilities in the EU’s financial system. The report identifies four main risks in the EU financial system, including: (i) “risks related to the UK’s withdrawal from the EU”; (ii) “persistent valuation risk in the context of an uncertain outlook for yields”; (iii) “low profitability of financial institutions”; and (iv) “rapid developments in FinTech.” In light of these risks, the report recommends that: (i) stakeholders “commi[t] to supervisory convergence, cross-border cooperation and transparency and avoidance of regulatory arbitrage”; (ii) “ESAs promote the mitigation of risks around valuation issues and abrupt reversals in yield levels by evaluating EU financial institutions’ capacities to deal with elevated stress scenarios”; (iii) “supervisors . . . pay particular attention to the composition of balance sheets”; (iv) “[insurance] policy makers and supervisors . . . focus their attention on the protection of policyholder interests”; and (v) with regards to FinTech, “supervisors should ensure compliance with regulatory obligations, while policy makers should consider amending and extending the regulatory framework where necessary.”
ESMA and EBA Publish Guidelines on Suitability of Members of Management Bodies and Key Function Holders
On 26 September, ESMA and EBA published their final joint Guidelines on the “assessment of the suitability of members of the management body and key function holders” under CRD IV and MiFID II. As the executive summary of the Guidelines explains, the directives aim to provide “common criteria to assess the individual and collective knowledge, skills and experience of members of the management body as well as the good repute, honesty and integrity, and independence of mind.” It also explains that the Guidelines: (i) “specify that all institutions have to assess the members of the management body”; (ii) “provide common criteria to assess the individual and collective knowledge, skills and experience of members of the management body as well as the good repute, honesty and integrity and independence of mind of members of the management body”; (iii) “set a framework for assessing the time commitment expected of members of the management body and specify how the number of directorships has to be counted, in the case of significant institutions”; (iv) “determine how diversity is to be taken into account in the selection process for members of the management body”; and (v) require institutions to “establish training policies and to provide for appropriate financial and human resources to be devoted to induction and training.” The Guidelines will enter into force on 30 June 2018.
European Commission Publishes Proposal for a Regulation on Free Flow of Non-Personal Data in the EU
On 13 September, the European Commission published a proposal for a regulation “on a framework for the free flow of non-personal data in the EU.” The proposed regulation aims to create a framework that: (i) “improv[es] the mobility of non-personal data across borders in the single market”; (ii) “ensur[es] that the powers of competent authorities to request and receive access to data for regulatory control purposes, such as for inspection and audit, remain unaffected”; and (iii) “mak[es] it easier for professional users of data storage or other processing services to switch service providers and to port data, while not creating an excessive burden on service providers or distorting the market.” The consultation period closes on 17 November 2017.
EuVECA and EuSEF – European Parliament Adopted Proposed Amending Regulation
On 14 September, the European Parliament voted to adopt the final text of the proposed regulation amending the European Venture Capital Fund (“EuVECA”) regulation and European social entrepreneurship funds (“EuSEF”) regulation. According to the press release, the proposed amending regulation would: (i) “widen the range of managers eligible to set up and manage EuVECA and EuSEF funds to include those with assets under management of more than €500 million”; (ii) “widen the range of firms that EuVECA can invest in to include unlisted companies with up to 499 employees”; (iii) “broaden the definition of enterprises that EuSEF can invest in to include ‘services and goods generating social return’”; (iv) “enable EuSEF and EuVECA registered managers to market their funds across the EU”; and (v) “give [ESMA] an oversight role to ensure that the funds are consistently registered and supervised.” The proposed amending regulation will come into force 20 days after publication in the Official Journal.
IDD – European Commission Adopts Regulations on Insurance Distribution
On 21 September, the European Commission adopted two delegated regulations supplementing the Insurance Distribution Directive (2016/97/EU) (“IDD”).
- Delegated regulation C(2017) 6218 addresses “product oversight and governance requirements for insurance undertakings and insurance distributors” and “specifies the criteria and practical details for the application of the [product oversight and governance] rules.”
- Delegated regulation C(2017) 6229 addresses “information requirements and conduct of business rules applicable to the distribution of insurance-based investment products,” and “aims at specifying the criteria and practical details for the application of the rules on conflicts of interest, on inducements and on the assessment of suitability and appropriateness.”
IDD – EIOPA Requests Feedback on Development of Q&As for IDD and Adopted Delegation Regulations
On 25 September, EIOPA issued a Survey to gather feedback from stakeholders regarding the development of Q&As on the IDD and the two Delegated Regulations adopted by the European Commission on 21 September. EIOPA issued the Survey to “collect questions from external stakeholders to build up a suitable ‘evidence base’ for its work” on developing Q&As. The consultation period closes on 11 October 2017.
OECD Publishes Report on Technology and Innovation in the Insurance Sector
On 8 September, the Organisation for Economic Co-operation and Development (“OECD”) published a report on technology and innovation in the insurance sector. The report “catalogues the relevant technologies that are being viewed as having the potential to bring innovation to the insurance sector” and examines: (i) the funding of “InsurTech”; (ii) “insurance intermediation and distribution models”; (iii) “the sharing economy and insurance”; (iv) “robo-advice and AI”; (v) “data aggregation and analytics”; and (vi) the “role of policy and regulation in InsurTech.”
IAIS Publishes Aggregate Report on Self-Assessment and Peer Review of ICPs 13 and 24
On 30 August, the International Association of Insurance Supervisors (“IAIS”) published an aggregate report of a thematic self-assessment and peer review on certain insurance core principles (“ICPs”). The assessment was conducted by an “Expert Team” consisting of representatives from IAIS member jurisdictions and the International Monetary Fund. The report assesses the observance by national authorities of ICP 13 (reinsurance and other forms of risk transfer) and ICP 24 (macroprudential surveillance and insurance supervision), finding that: (i) “there seems to be regional differences in the level of observance of the various Standards under the two ICPs”; (ii) with regards to ICP 13, “there seems to not be enough differentiation in the supervision of the ceding insurer’s reinsurance risk management”; and (iii) with regards to ICP 24, “although nearly all supervisors report carrying out macroprudential surveillance of their insurance sector, the practice seems to be lacking in systematization, and formalization.” Among other recommendations, the Expert Team finds that the IAIS should consider: (i) with regards to reinsurance, providing “additional clarity and guidance on reinsurance-specific supervisory considerations”; and (ii) with regards to macroprudential surveillance and policy, providing “guidance on tools and other resources that can contribute to carrying out macroprudential practices in a more systematic fashion, and additional clarity on the ‘division of labour’ between macroprudential surveillance and supervision goals and activities.”
IAIS Publishes Report on Supervisory Capacity Building and Development Needs
On 30 August, the IAIS published a report containing the results of a joint survey conducted with the Access to Insurance Initiative of forty-five jurisdictions (making up one-third of IAIS members and “well-distributed by nature of the jurisdiction and IAIS region”) regarding the capacity building and development needs of insurance supervisors. Specifically, the report provides key findings regarding: (i) institutional information; (ii) staffing and professional development; and (iii) “promotion of capacity building resources.”
- Institutional Information: The report found: (i) “most respondents supervise an average of three sectors among insurance, pensions, banking, securities and other sectors”; and (ii) “during the next three years, respondents plan to give the highest priority to macroprudential supervision and supervision of conventional insurance market on various aspects, including prudential supervision of underwriters, market conduct supervision of underwriters and intermediaries, as well as the development of the market.”
- Staffing and Professional Development: The report found: (i) “during the next three years, respondents expect greater percentages of new staff entrants to be supervisors, rather than senior management and non-supervisors”; (ii) “approximately one-half of respondents indicate that the financial resources available for capacity building of insurance supervisors are usually sufficient”; and (iii) “approximately one-half of the respondents rely on individuals or their managers to establish such plans.”
- Promotion of Capacity Building Resources: The report found: (i) “during the next three years, with respect to the ICPs, several fundamental aspects of prudential supervision are the highest priority areas for the capacity building of insurance supervisors,” including ICP 8 (risk management and internal controls) with the highest priority, and ICP 17 (capital adequacy), ICP 7 (corporate governance), and ICP 16 (enterprise risk management for solvency purposes) with the second highest priority; and (ii) “the top five ICPs requiring more clarification are ICP 8, ICP 7, ICP 16, ICP 17 and ICP 13 related to Reinsurance and Other Forms of Risk Transfer.”
IAIS Publishes Application Paper Regarding Mutuals, Cooperatives, and Community-Based Organizations
On 19 September, the IAIS published an Application Paper on the “regulation and supervision of mutuals, cooperatives and community-based organisations in increasing access to insurance markets.” The Application Paper provides “guidance on the way ICPs could be applied in a proportionate manner [to mutuals, cooperatives and community-based organisations] which should contribute to removing unnecessary barriers by disproportionate regulation and supervision, while at the same time ensuring appropriate policyholder protection.”
ESMA and NCAs Finalise Updated Work Plan for Opinions on Pre-Trade Transparency Waivers and Position Limits Issued under MiFID II and MiFIR
- Pre-Trade Transparency Waivers: Noting the “high number and complexity of pre-trade transparency waivers that need to be submitted and assessed,” ESMA indicated that it intends to: (i) finalize all opinions on equity instrument waivers by the end of 2017; and (ii) finalize as many opinions on non-equity instrument waivers as possible before 3 January 2018, although it is unlikely that they will be able to issue opinions on a majority of waiver notifications. In the event ESMA does not finalize an opinion, ESMA indicated that the NCAs “will grant the requested waivers based on their own compliance assessment only,” subject to certain conditions.
- Position Limits for Commodity Derivatives: ESMA and the NCAs indicated that “it will not be possible to finalise and publish all the position limit opinions for liquid commodity derivative contracts by the end of the year.” In light of this, ESMA indicated that: (i) “NCAs will publish limits ahead of [ESMA’s] opinions”; (ii) “those limits will enter into force, and be monitored by NCAs, on 3 January 2018”; and (iii) “following the issuance of [ESMA’s] opinions, all NCAs [will] modify the position limits in accordance with the opinion, or provide ESMA with a justification for why the change is not necessary.”
MiFIR – European Commission Decides Against Need to Temporarily Exclude Exchange-Traded Derivatives from Non-Discriminatory Access Provision
On 11 September, the European Commission published a report to the European Parliament and the Council regarding the “need to temporar[ily] exclude exchange-traded derivatives [(“ETDs”)] from the scope of Articles 35 and 36 of [MiFIR]”. Articles 35 and 36 of MiFIR mandate that central counterparties (“CCPs”) and trading venues grant each other access to the services they provide on an “open and non-discriminatory” basis. MiFIR foresaw that that “open access” for ETDs between CCPs and trading venues “may raise risks and have potential drawbacks that could outweigh the policy objectives of enhanced competition.” Thus, Articles 35 and 36 of MiFIR established conditions under which access may be denied. Based on a risk assessment produced by ESMA on 4 April 2016 and the examination of several potential risks relating to the open access of ETDs between CCPs and trading venues, the report concludes that “the current regulatory framework in MiFIR and EMIR appropriately addresses the potential risks identified,” and as such, “it is not necessary to temporary exclude [ETDs] from the scope of Articles 35 and 36 of MiFIR.”
On 12 September, ESMA published updated Q&As on MiFID II/MiFIR relating to market structure following the European Commission’s decision against temporarily excluding ETDs from Articles 35 and 36 of MiFIR. The updated Q&As cover: (i) “timing and procedure of notification to ESMA for temporary opt-out under Article 36(5) of MiFIR”; (ii) the application by a trading venue for exemptions under Article 36(5) or Article 54(2) of MiFIR; (iii) the application by a CCP or trading venue for “permission to avail itself of transitional arrangements under Article 54(2) of MiFIR”; and (iv) the access rights of CCPs to trading venues following decision by a trading venue to temporarily opt-out under Article 36(5) of MiFIR.
On 15 September, ESMA published a policy containing the procedures for trading venues to follow if they decide to temporarily opt out of the open access provisions for ETDs under MiFIR. While trading venues are required to “provide access . . . to CCPs that wish to clear transactions executed on those trading venues,” trading venues that fall below a “certain threshold” when trading in ETDs “may notify ESMA and its competent authority of its intention to temporarily opt-out from the access provisions with respect to those instruments.”
MiFID II/MiFIR – ESMA Publishes Revised Transparency Calculations
non-equity instruments under MiFID II/MiFIR. The updated TTC include, among other things: (i) calculations for bonds, which were excluded from the 3 July 2017 opinion; (ii) “information on OTC markets using information provided by TRAX”; and (iii) corrections and recalculations for credit derivatives and equity derivatives required due to issues in the data submitted by trading venues in the 3 July 2017 opinion. ESMA also published an updated set of FAQs on the TTC.
MiFID II – Adoption of Delegated Regulation on the Definition of Systematic Internaliser
On 25 September, the Council of the EU decided not to object to Commission Delegated Regulation (C(2017) 5812) adopted by the Commission on 28 August, amending Delegated Regulation (EU) 2017/565 regarding the definition of systematic internalisers for the purposes of MiFID II. Noting that recent “industry initiatives [have built] on the ambiguity around the notion of ‘trading on own account when executing client orders’ which define the activity of systematic internalisers,” the European Commission determined that it was necessarily to amend Delegated Regulation (EU) 2017/565 to “specify that a systematic internaliser is not allowed to engage, on a regular basis, in the internal or external matching of trades via matched principal trading or other types of de facto riskless back-to-back transactions in a given financial instrument outside a trading venue.” If the European Parliament does not object to the Regulation, it will enter into force 20 day after its publication in the Official Journal.
MiFID II – European Commission Adopts Delegated Regulation on RTS for Data Reporting Service Providers
On 26 September, the European Commission adopted a Commission Delegated Regulation (C(2017) 6337) amending Commission Delegated Regulation (EU) 2017/571 supplementing MiFID II regarding RTS “on the authorisation, organisational requirements and the publication of transactions for data reporting services providers.” If adopted by the European Parliament and the Council, the Delegated Regulations will enter into force 20 days after its publication in the Official Journal and generally apply from 3 January 2018, with certain provisions applying between 1 January 2019 and 3 September 2019.
MiFIR/EMIR – European Commission adopts Delegated Regulation on Indirect Clearing Arrangements
On 22 September, the European Commission adopted two Delegated Regulations establishing regulatory technical standards (“RTS”) on indirect clearing arrangements for OTC derivatives and ETDs.
- Commission Delegated Regulation (C(2017) 6270) amending Commission Delegated Regulation (149/2013/EU) supplementing EMIR;
- Commission Delegated Regulation (C(2017) 6268) supplementing MiFIR.
Both Delegated Regulations indicate that they aim to: (i) “simplify and clarify the requirements that relate the management of the default of a client providing indirect clearing services”; (ii) “adapt account structures in order to rationalise the offering of indirect clearing services”; (iii) “allow indirect clearing services to be provided in chains going beyond the client of a direct client provided that appropriate and equivalent protection is ensured throughout the chain”; and (iv) “set out homogeneous requirements for indirect clearing arrangements relating to both OTC and ETD derivatives.” If adopted by the European Parliament and the Council, the Delegated Regulations will enter into force 20 days after its publication in the Official Journal and apply from 3 January 2018.
Market Abuse Regulation – ESMA Publishes Updated Q&As
On 1 September, ESMA published updated Q&As on the implementation of the Market Abuse Regulation (596/2014/EU) (“MAR”) The updated Q&A clarifies aspects of the application of MAR, including: the scope of firms subject to the provision to detect and report suspicious orders and transactions, the scope of financial instruments subject to the market sounding regime, and persons subject to insider list requirements.
On 28 August, ESMA published a guidelines compliance table describing whether competent authorities have informed ESMA that they comply, do not comply, or intend to comply with ESMA’s Guidelines (ESMA/2016/1480) on “information relating to commodity derivatives markets or related spot markets for the purpose of the definition of inside information on commodity derivatives” under MAR. All member states, with the exception of Croatia and Latvia (which have indicated that they intend to comply with the guidelines by 31 December 2017 and 1 October 2017 respectively), have informed ESMA that they comply with the guidelines.
ISDA Publishes White Paper Proposing Risk-Based Framework for Cross-Border Derivatives Comparability Determinations
On 18 September, the International Swaps and Derivatives Association (“ISDA”) published a white paper titled “cross-border harmonization of derivatives regulation regimes.” The paper focused on the cross-border framework introduced by the CFTC. Noting that the current international derivatives framework has resulted in “duplication, complexity and unnecessary compliance challenges for derivatives users,” the paper: (i) “proposes a risk-based framework for the evaluation and recognition of the comparability of derivatives regulatory regimes of foreign jurisdictions”; (ii) “establishes a set of risk-based principles that may be used as a tool in the assessment of derivatives regulatory regimes of foreign jurisdictions”; and (iii) “analyzes the derivatives regulatory frameworks of representative G-20 nations against the proposed risk-based principles.” ISDA indicated that it is prepared to assist the CFTC and other regulators to harmonize cross-border regulatory regimes.
Proposed Regulation on CCP Recovery and Resolution Framework
On 20 September, the ECB published an Opinion on the proposal for a Regulation on a framework for the recovery and resolution of CCPs and amending Regulation (EU) No 1095/2010 establishing ESMA, amending Regulation EMIR, and amending Regulation (EU) 2015/2365 on transparency of securities financing transactions and on the reuse of assets (“SFTR”). The Opinion indicated that while the ECB “strongly supports the Commission’s initiative to establish a dedicated Union framework for the recovery and resolution of [CCPs] . . . the proposed regulation could be further enhanced . . . in four areas,” including: (i) “the critical role of clearing participant . . . to estimate reliably and manage their potential exposures under the proposed regulation . . . [while having] sufficient flexibility for devising their actions”; (ii) “ensur[ing] the continuity of the CCP’s critical functions without incurring taxpayer losses”; (iii) complementing “CCP recovery and resolution on a standalone basis [with] horizontal cooperation to ensure their consistency and effective interaction,” such as encouraging cooperation between ESMA, European System of Central Banks, ECB, and EBA; and (iv) the “need for consistency of recovery and resolution plans . . . in line with relevant international standards.”
On 25 September, the European Parliament’s Committee on Economic and Monetary Affairs (“ECON”) also published a draft report (2016/0365(COD)) on the proposal for a Regulation on a framework for the recovery and resolution of CCPs. The draft report indicated that the proposed regulation will “result in the orderly use of the necessary tools and put in place safeguards to deal with even the most extreme scenarios in recovery and also in resolution [of CCPs] where appropriate.”
ISDA Publishes Recommendations Regarding CCP Recovery and Resolution Framework
On 18 September, ISDA published a paper titled “Safeguarding Clearing: The Need for a Comprehensive CCP Recovery and Resolution Framework.” The paper includes the following recommendations: (i) “[a] resolution regime for CCPs should indicate a time at which resolution could commence, but should allow flexibility for recovery to continue beyond that time”; (ii) “[c]learing participants should have maximum transparency regarding the key elements of, and triggers for, a CCP resolution”; (iii) “[s]ubject to safeguards, variation margin gains haircutting could be used to allocate losses at the end of a CCP’s default waterfall”; (iv) “subject to safeguards, partial tear-ups could be used to rebalance a CCP’s book if an auction or similar voluntary mechanism fails to do so”; (v) “CCP assessments on clearing members must be capped in aggregate across recovery and resolution”; (vi) “initial margin haircutting should never be permitted”; (vii) “forced allocation of positions to non-defaulting clearing members should never be permitted”; (viii) “clearing participants suffering losses beyond a certain point in a CCP recovery or resolution must receive claims that position them senior to existing CCP equity holders”; (ix) “it is appropriate for clearing participants to bear at least a portion of some non-default losses, but CCPs and their shareholders must bear the risk of non-default losses that are solely within their control”; and (x) “access to liquidity from central banks on standard market terms is necessary to support CCP recovery and resolution.”
IOSCO and CPMI Publish Technical Guidance on Harmonization of Unique Product Identifier
On28 September, IOSCO and the CPMI published technical guidance on a uniform global Unique Product Identifier (“UPI”) applying to OTC derivatives transactions. The technical guidance overs topics related to: (i) “the technical principles applicable to the UPI”; (ii) “the UPI reference data elements required for each OTC derivatives asset class”; (iii) “the identification of underlying assets and benchmarks of OTC derivative products”; and (iv) “the UPI code structure.” The technical guidance indicated that it “does not address the work concerning the governance arrangements or the implementation of the UPI.”
Benchmarking – ECB Announces Plan to Publish New Unsecured Oversight Interest Rate
On 21 September, the European Central Bank (“ECB”) announced its intention to develop a new “euro unsecured oversight interest rate based on data available to the Eurosystem . . . before 2020.” The ECB indicated that the “interest rate will be based entirely on transactions in euro that are reported by banks in accordance with the ECB’s money market statistical reporting” and that it would “complement existing benchmark rates produced by the private sector and serve as a backstop reference rate.”
UPCOMING EVENTS AND DEADLINES
- 1 October: International Association of Insurance Supervisors consultation on its Insurance Core Principle 24 regarding Macroprudential Surveillance and Insurance Supervision closes.
- 5 October: Basel Committee on Banking Supervision and International Organization of Securities Commissions consultation on “criteria for identifying simple, transparent and comparable short-term securitizations” closes.
- 11 October: EIOPA consultation on the development of Q&As for the IDD and Adopted Delegation Regulation closes.
- 13 October: ESMA consultation on Guidelines on certain aspects of the MiFID II Suitability Requirement closes.
- 15 November: European Commission consultation on post-trade in a Capital Market Union: Dismantling Barriers and Strategy for the Future closes.
- 17 November: European Commission consultation on the review of the ESAs closes.