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Comment Letters

2017

ICSA Response to FSB consultation on framework for impact assessment of G20 reforms

   JSDA /sites/default/files/JSDA%20Comments%20to%20Proposed%20Framework%20for%20Post-Implementation%20Evaluation%20o....pdf

   ICMA /sites/default/files/ICMA%20FSB%20Framework%20response%20May%202017_final.pdf

   GFMA /sites/default/files/GFMA_ISDA_JFMC_post_crisis_evaluation_framework_CP%20%20response_11%20May.pdf

2016

ICSA Response to the FSB Questionaire for Industry Associations: Stocktake of Efforts to Strengthen Goverance Frameworks to Mitigate Misconduct Risk /sites/default/files/ICSA%20Response%20-%20FSB%20Questionnaire%20on%20Governance%20and%20Misconduct%20%20Risk%20-%203%20November%202016_0.pdf

ICSA Response to IOSCO Liquidity Consultation /sites/default/files/ICSA%20-%20Public%20Comment%20-%20Examination%20of%20Liquidity%20of%20the%20Secondary%20Corporate%20Bond%20Markets%20-%2029%20Sep%202016_0.docx

ICSA Response Call for evidence: EU regulatory framework for financial services /sites/default/files/ICSA%20-%20EU%20Call%20for%20Evidence%20-%2025%20Jan%2016.pdf

2015

Bond Market Liquidity: Key Issues and Member Association Publications (November 2015)
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Letter from the ICSA CEO Tackling Systemic Risks: Are they extinguished? Or do they lurk in the shadows?
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Letter from the ICSA CEO Global Credit Markets at a Crossroads: Implications for Canada
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ICSA Letter to Susan Bergstraesser regarding Corporate Bond Market Liquidity (July 2015)
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2014

ICSA Chairman's Letter - Building Bond Market Liquidity in Europe: A Key Step to Stimulating Growth and Reversing Disinflation (June 2014)
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2013

Letter to IOSCO regarding Task Force on Cross-Border Regulation (September 6, 2013)
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Letter to the OECD regarding Best Practice Principles for the Governance of Regulators (August 30, 2013)
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Letter on proposed FTT to the European Commission (April 16, 2013)
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Letter to IOSCO Board on promoting mutual recognition among securities regulators (April 2, 2013)
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Letter to IOSCO on regulatory consultation (March 1, 2013)
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Letter to the FSB on regulatory consultation (February 28, 2013)
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2012

Letter to European Commission for Promoting a Global Mutual Recognition Framework (October 19, 2012)
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Letter to IOSCO on the Development of Global Principles for Mutual Recognition (September 6, 2012)
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Comment Letter to CFTC on the Proposed Interpretive Guidance on the Cross-Border Application of Certain Swaps Provisions of the Commodity Exchange Act (August 27, 2012)
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Second Letter to FSB on Reasserting the Importance of Multilateral Global Coordination (August 8, 2012)
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Letter to FSB on the Importance of Multilateral Global Coordination (May 23, 2012)
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Public Comment on Suitability Requirements with Respect to the Distribution of Complex Financial Products (May 21, 2012)
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Letters to the Mexican Presidency of the G20 regarding the need to widen the dialogue between the G20 and the financial services industry (March 2012)
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Proposal to Widening the Dialogue between the G20 and the Financial Services Industry (March 23, 2012)
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Comments on Proposed Restrictions on Proprietary Trading and Certain Interests in, and Relationships with, Hedge Funds and Private Equity Issued by U.S. Agencies (Volcker Rule) (February 13, 2012)
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2011

Comments on the Proposed Revisions to the FATF 40+9 Recommendations (December 14, 2011)
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Letter to the FSB regarding a proposed global financial transactions tax (November 2011)
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Response to September FSB LEI Workshop (November 22, 2011)
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Response to Foreign Account Tax Compliance Act (FATCA) (November 22, 2011)
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Letter to European Commission on Financial Transaction Tax (FTT) (October 27, 2011)
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Trade Association Letter on Legal Entity Identifier (LEI) (September 12, 2011)
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Comments on the Proposed Revisions to the FATF 40+9 Recommendations (September 16, 2011)
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Letter to Sub-Committee on EU Sovereign Debt Markets (September 7, 2011)
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Public Comment on IOSCO Consultation Report, "Regulatory Issues Raised by the Impact of
technological Changes on Market Integrity and Efficiency" (August 12, 2011)
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Letter to French Treasury regarding the US Foreign Account Tax Compliance Act (July 2011)
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Response to Implications of the Foreign Account Tax Compliance Act (FATCA) (June 28, 2011)
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Comments on the Proposed Revisions to the FATF 40+9 Recommendations (January 7, 2011)
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2010

Letter to FATF regarding FATF Recommendations on Beneficial Ownership (October 2010)
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Letter to BCBS regarding Report on Countercyclical Capital Buffers (September 2010)
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Letter to BCBS regarding request for further consultation (July 2010)
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Comments on Basel Committee's Consultation Package Issued December 2009 (April 16, 2010)
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ICSA Congratulates the Republic of Korea on their Role as Chairman of the G20 (February 17, 2010)
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Comments Regarding IMF Study on Financial Sector Taxation (February 1, 2010)
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2009

Letter to Financial Stability Board Regarding Enhanced Industry Consultation (December 16, 2009)
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Letter to Basel Committee on Banking Supervision Regarding Enhanced Industry Consultation (December 2, 2009)
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Letter to FATF regarding proposed policy options for combating proliferation financing (November 2009)
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Letter to FATF regarding Joint Work on Recommendation 9 (November 2009)
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Comments Regarding IOSCO's Consultation Report on Transparency of Structured Finance Products (November 13, 2009)
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Letter to IOSCO regarding agenda for upcoming stakeholders' meeting (October 2009)
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Comments on IOSCO's Impact on and Response of Emerging Markets to the Financial Crisis Report (July 21, 2009)
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Industry Consultation with the Financial Stability Board (June 19, 2009)
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Comments on IOSCO's Unregulated Financial Markets and Products Report (June 15, 2009)
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Comments on IOSCO's Short Selling Consultation Report (May 4, 2009)
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Comments on IOSCO's Hedge Fund Oversight Consultation Report (April 30, 2009)
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Letter to G20 (March 3, 2009)
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2008

Joint Letter to the Financial Stability Board (FSB) regarding Securities Issues and the new Global Financial Architecture (December 2008)
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Comments on IOSCO's Issues Paper on Point of Sale Disclosure to Retail Investors (September 25, 2008)
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Comments to the SEC on Proposed Amendments to Rule 15a-6 (September 8, 2008)
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Comments on Proposed EU Directive on the Authorization, Operation and Supervision of Credit Rating Agencies (September 5, 2008)
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Comments on IOSCO's Consultation Report on the Role of Credit Rating Agencies in Structured Finance Markets (April 25, 2008)
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2007

Comment Letter on the Hedge Fund Working Group's Consultation Document (December 14, 2007)
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Comment Letter on the U.S. Treasury's Review of the U.S. Regulatory Structure for Financial Institutions (November 21, 2007)
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Letter to IOSCO regarding proposed agenda for meeting with stakeholders (August 2007)
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Letter to IOSCO regarding Report on Overview of the Work of IOSCO's Technical Committee (June 2007)
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Comment Letter on IOSCO's "An Overview of the Work of IOSCO's Technical Committee" (June 8, 2007)
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Comment Letter on IOSCO's "Market Intermediary Management of Conflicts of Interest that Arise in Securities Offerings" (May 25, 2007)
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Letter to IOSCO proposing measures to enhance consultation with stakeholders (April 2007)
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Letter to FATF regarding proposed principles for risk-based approach to AML/CFT (April 2007)
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Letter to IOSCO regarding Enhanced Consultation between ICSA and IOSCO (March 2007)
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Comment on IOSCO's Consultation Report on Soft Commission Arrangements1 (March 15, 2007)
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Letter to Committee on Capital Market Regulation regarding better regulation (January 2007)
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2006

Letter to IOSCO proposing enhanced consultation with ICSA (November 9, 2006)
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Comment Letter to the Autorite des Marches Financiers (AMF) Regarding its Proposed Better Regulation Initiative (September 28, 2006)
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Comment Letter to IOSCO Regarding its "Regulatory Issues Arising From Exchange Evolution" (June 2, 2006)
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Second Comment Letter to IOSCO Regarding its "Regulatory Issues Arising From Exchange Evolution" (June 2, 2006)
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2005

Letter to IOSCO regarding consultation with ICSA (June 2005)
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Letter to FATF Regarding Consultation with Global Securities Industry on AML Measures (May 17, 2005)
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IOSCO's Draft "Consultation Policy and Procedures" (January 7, 2005)
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2004

Letter to IOSCO regarding IOSCO's participation in the International Forum for Investor Education (December 2004)
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Letter to IOSCO regarding ICSAs Statement on Regulatory and Self-Regulatory Consultation Practices (October 2004)
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Letter to IOSCO regarding ICSA's work on Investor Education (September 2004)
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Letter to IOSCO’s EMC regarding ICSAs Business Continuity Planning Guidelines for Securities Firms (June 2004)
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Letter to IOSCO regarding ICSAs Business Continuity Planning Guidelines for Securities Firms (June 2004)
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Letter to IOSCO regarding ICSA's Principles and Best Practices for Investor Education (March 26, 2004)
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1999

Letter to U.S. President Clinton on Year 2000 Readiness (June 1999)
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Letter to IOSCO Regarding Securities Activities on the Internet (May 1999)
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