Mutual Funds and, more recently, semi-transparent ETPs employ limited or delayed reporting of their holdings to protect their IP. With the plan to introduce a monthly look-through requirement, proposed under 325j(1)(a), what is the expectation for banks to calculate capital requirements for these kinds of instruments?
IM
IHS Markit
Company · United Kingdom
not in the EU Transparency RegisterThis organization files on consultations without a register number, so its record here is built from its filings alone. Register facts — staff, costs, accreditations — are not available for it.
4
positions filed
in the 583 files tracked
4
legislative files
of 583 tracked
4
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
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Their record over time
IHS Markit filed 4 positions between 15 Apr 2020 and 25 Nov 2021, across 4 of the 583 legislative files tracked here, attaching a full position paper 4 times.
2020 · 2 filed2021 · 2 filed
What they argued
IHS Markit greatly appreciates the opportunity to comment on the “New EU System For The Avoidance of Double Taxation and Prevention of Tax Abuse In The Field of Withholding Taxes”. Our comments in support of this initiative have been submitted via a separate document. We look forward to working with you on this initiative.
We agree with the EC that green bonds play an increasingly important role in asset finance and we expect that this trend will continue and increase in importance for fixed income investors. Recognising this increasing importance and the role data will play, firms such as IHS Markit are currently engaged in research and development activities around what bond level Green/ESG content could look like.
IHS Markit is a leading benchmark administrator. IHS Markit Benchmark Administration Ltd. (IMBA UK) has been FCA authorised since July 2017, and Markit N.V. (IMBA EU) received AFM authorisation in December 2019. These administrators provide more than 29,000 benchmarks across financial, economic and commodity underlyings, including proprietary benchmarks and benchmarks administered for clients.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers — not evidence of coordination, and we do not suggest any.
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