IIF Authors

Status: Will be live at 02/24/2017 00:00

IIF-GFMA Joint Response - FSB's Guidance on Continuity of Access to Financial Market Infrastructures

Friday, February 24, 2017

In the response letter IIF and GFMA strongly support the objectives of the Guidance including enhancing transparency and communication between FMIs, FMI intermediaries, firms and the relevant supervisory and resolution authorities to further advance work in this area.

It should be clarified that custodian banks are not in any way classified as FMIs and should instead be treated, for the purposes of this Guidance only, as FMI intermediaries which better reflects the services they provide.

Further, it is essential to distinguish between FMIs and FMI intermediaries in each portion of the Guidance. There are a number of important differences which need to be considered and reflected in the Guidance; conflating the two may lead to unnecessary confusion and complexity.