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Regulation of Financial Market Infrastructures (FMIs)

Central Banking and Monetary Policy November 30, 2025
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Introduction

Financial Market Infrastructures (FMIs) are the core utilities of the financial system, encompassing payment systems, Central Counterparties (CCPs), and securities depositories. The rigorous regulation of these entities is essential to prevent systemic crises. This course provides an in-depth, legal and regulatory examination of the principles governing FMIs, centered on the internationally agreed **CPMI-IOSCO Principles for FMIs (PFMIs)**. Participants will learn how to apply these standards to various FMI types, analyze the legal foundations for risk mitigation, and understand the critical regulatory expectations for governance, risk management, and the recovery and resolution of systemically important FMIs.

Objectives

Upon completion of this program, participants will be able to:

  • Analyze the structure and mandate of the **CPMI-IOSCO Principles for FMIs (PFMIs)** and their scope of application.
  • Evaluate an FMI's compliance with PFMIs across credit, liquidity, settlement, and operational risk.
  • Understand the legal requirements for finality, irrevocability, and the enforceability of close-out netting.
  • Describe the regulatory frameworks for FMI governance, transparency, and information disclosure.
  • Assess the specific risks and regulatory requirements for different FMI types (e.g., CCPs, CSDs).
  • Examine the principles and requirements for FMI **recovery and resolution planning (RRP)**.
  • Understand the coordination and legal challenges of cross-border and interlinked FMI regulation.
  • Formulate policy and regulatory amendments to address emerging FMI risks (e.g., cyber, DLT).

Target Audience

  • Central Bank FMI Oversight and Regulatory Staff
  • Legal and Compliance Officers for FMIs and Central Banks
  • FMI Risk Management and Internal Audit Professionals
  • Government Policy Makers on Financial Regulation
  • Senior Management of Clearing Houses and Depositories
  • International Financial Institution Regulatory Experts

Methodology

FMI RRP case studies and simulation, PFMIs compliance audit group project, Legal analysis of netting and finality legislation, Policy debates on CCP loss allocation, Role-playing regulatory examination of FMI governance, Structured discussions on DLT regulation.

Personal Impact

  • Master the international regulatory framework for Financial Market Infrastructures.
  • Acquire specialized knowledge in applying PFMIs to diverse FMI models.
  • Enhance analytical skills for assessing governance, legal, and systemic FMI risks.
  • Gain proficiency in the regulatory requirements for FMI recovery and resolution.
  • Improve career prospects in FMI oversight, regulation, and compliance.
  • Be able to contribute to robust regulatory policy formulation and enforcement.

Organizational Impact

  • Ensure institutional compliance with all international FMI regulatory standards.
  • Strengthen the governance and risk management processes of FMI operations.
  • Enhance the organization's ability to navigate cross-border regulatory complexities.
  • Improve the rigor of internal audit and risk assessment of FMI activities.
  • Facilitate better communication and dialogue with regulatory authorities.
  • Reduce the risk of systemic failure by adhering to best-practice regulation.

Course Outline

Unit 1: Foundations and the PFMIs Framework

Section 1: Defining and Classifying FMIs
  • The distinction between Payment Systems, CCPs, CSDs, and Trade Repositories.
  • Criteria for determining systemic importance and regulatory designation.
  • The history and motivation for the development of international FMI standards.
  • The role of the Financial Stability Board (FSB) in FMI policy coordination.
Section 2: Principles for Financial Market Infrastructures (PFMIs)
  • Overview of the 24 principles and the responsibilities for authorities.
  • In-depth focus on Principle 1 (Legal basis) and Principle 2 (Governance).
  • The framework for risk management: PFMIs 3-17 (Credit, Liquidity, Settlement, Custody, etc.).
  • PFMIs for efficiency, transparency, and broad access (PFMIs 18-24).

Unit 2: Risk-Specific Regulatory Requirements

Section 1: Credit and Liquidity Risk Regulation
  • Regulatory expectations for margin models, collateral eligibility, and haircuts (PFMI 5).
  • Liquidity risk management requirements for CCPs, including the coverage of liquidity shortfalls (PFMI 7).
  • Regulatory treatment of settlement risk in DvP and PvP systems (PFMIs 11 and 12).
  • Stress testing requirements for credit and liquidity resources.
Section 2: Operational and Legal Risk Regulation
  • Regulatory mandate for operational risk management and business continuity (PFMI 17).
  • Requirements for cyber resilience and secure recovery for critical systems.
  • The legal requirements for ensuring finality and irrevocability of transfers (PFMI 8).
  • Regulatory stance on the use of new technologies (e.g., DLT) in FMI operations.

Unit 3: Governance, Transparency, and Resolution

Section 1: Governance and Disclosure
  • Regulatory expectations for the FMI's board composition, skill, and independence.
  • The requirement for clear and comprehensive rules, procedures, and contracts.
  • Regulatory mandate for transparency and public disclosure of rules and risk data (PFMI 23).
  • Management of conflicts of interest and participant eligibility.
Section 2: Recovery and Resolution Planning (RRP)
  • Regulatory mandate for the FMI to develop a credible **Recovery Plan**.
  • The role and powers of the Resolution Authority in FMI failure.
  • Legal and policy challenges of cross-border resolution and resource sharing.
  • Assessing the adequacy of the FMI's loss allocation scheme.

Unit 4: Cross-Border and Emerging Issues

Section 1: Interoperability and Coordination
  • Regulatory challenges of interlinked FMIs (e.g., between a CCP and an SSS).
  • The need for cooperative oversight and information-sharing agreements across jurisdictions.
  • Regulatory approach to new global or multilateral FMIs.
  • Regulatory implications of the shift to global messaging standards (ISO 20022).

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Upcoming Sessions

09 Feb

Amsterdam

February 09, 2026 - February 13, 2026

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02 Mar

Paris

March 02, 2026 - March 06, 2026

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13 Apr

Bangkok

April 13, 2026 - April 17, 2026

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