IMA responds to consultations: IMA has published its responses to several consultations:

  • on the European Commission proposals for countercyclical capital buffers: it has responded to the Commission's question on whether investment firms should be subject to such a requirement. It points out that its members, as asset managers, do not trade on own account nor accept deposits, and all client assets are segregated and held with an independent custodian. On that basis, it would be inconsistent with the principles behind the buffer to require such firms to hold one;
  • on Treasury's draft legislation on the bank levy: it welcomes the fact that standalone asset managers will fall outside the scope of Treasury's proposals but is worried about its impact on asset managers within banking groups. It thinks it should be irrelevant whether the managers are within banking groups. It also thinks genuine third party liabilities of asset managers in a banking group should be excluded from the scope of the levy;
  • on Treasury's proposals for special administration regimes for investment firms: it thinks more clarity is needed on what is a "client asset". It generally supports the proposals, including the flexibility the proposals give to the return of client assets; and
  • on FSA's proposals on platforms: it supports more transparent markets but wants FSA to consider some unforeseen consequences. It sees an opportunity for providers and distributors to facilitate adviser charging in some cases but not others and that this may have obvious and unexpected consequences.