ALFI responds to the EU Commission on the CSDR Refit proposal

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 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.

Regarding the buy-in implementation, we are still of the view that this route should only be optional and not mandatory.

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View the ALFI response.