Association Française des Professionnels des Titres (« AFTI ») is the French association
representing the post- trade industry. All 100 members of AFTI 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.
AFTI and FBF fully support the FSB initiative to introduce appropriate resolutions plans for non-Bank financial institutions as they play an increasing role in the operation and sustainability of financial markets and potentially concentrate high volumes of activities. Thus, in a number of circumstances, recovery & resolution plan are to be developed with the objectives to identify practical, economically viable solutions with no unintended effects on the whole range of market participants.
As the voice of the French banks and post-trade market players, we would like to make specific comments on the elaboration and the implementation of resolution plans as well as on the annex to the FSB consultation document related to the protection of assets.
Our recommendations are issued in one hand from the perspective of custodians regulated as banks and providing a vast range of securities services (local and global custody, depositary function and asset servicing, issuers services, etc.), and on the other hand, as representatives of part of the non-banking sector in particular FMI’s since Euroclear France and L.C.H Clearnet SA are AFTI members.
We therefore think we have a large expertise on the topics addressed by the FSB document and a real added-value on the comments we address and seem us well-balanced.