We appreciate the opportunity to respond to this important consultation and remain gladly at the disposal of the European Commission staff to elaborate on any of our responses.
Capital markets
Investment managers, acting on behalf of their retail and institutional clients, are among the largest investors in financial markets. They represent a key component of the market’s “buy-side” segment.
In representing the interests of its members on wholesale capital market issues, EFAMA advocates for fair, deep, liquid, and transparent capital markets, supported by properly regulated and supervised market infrastructure.
EFAMA Position on the draft Joint Guidelines of ESAs regarding customer due diligence under Anti-Money Laundering Directive
EFAMA is closely monitoring the recent regulatory developments in the field of anti-money laundering and counter-terrorist financing, in particular the due diligence duties of the asset management sector. EFAMA is embracing the objective of enhancing transparency and accessibility to the beneficial ownership information and also fully acknowledges the importance of obtaining accurate identification and verification data of natural and legal persons for fighting money laundering and terrorist financing.
EFAMA's reply to ESMA's CP on RTS specifying the scope of the consolidated tape for non-equity financial instruments
EFAMA supports every efforts made to enhance financial markets regulation which reinforces the stability and the transparency of the financial system.
In that perspective, EFAMA welcomes the opportunity to comment on the ESMA Consultation Paper on RTS specifying the scope of the consolidated tape for non-equity financial instruments. We consider that a consolidate tape (“CT”) is a key positive factor for price formation and transparency.
Prior to replying to the consultation, we wish to make the following general remarks
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Industry Approach to CSDR Settlement Discipline Regime
The Joint Associations1 welcome clarification from ESMA that national competent authorities are expected not to prioritise supervisory actions in relation to the application of the CSDR buy-in regime.2
Joint Statement on EU Commission proposal for revised Market in Financial Instrument Regulation (MiFIR)
We see great value in the creation of a consolidated tape to support Europe’s capital markets. However, we qualify that statement with a reminder that the framework for a successful consolidated tape should
i) address the known market failure around market data costs,
Household Participation in Capital Markets
This report analyses the progress made in recent years by European households in allocating more of their financial wealth to capital market instruments (pension plans, life insurance, investment funds, debt securities and listed shares) and less in cash and bank deposits. It also includes policy recommendations on improving retail participation in capital markets, including for the Retail Investment Strategy currently under discussion.
Some key findings include:
Buy-side use-cases for a real-time consolidated tape
A real-time consolidated tape, provided it is made available at a reasonable cost, will bring many benefits to European capital markets. A complete and consistent view of market-wide prices and trading volumes is necessary for any market, though this is especially true for the EU where trading is fragmented across a large number of trading venues. A real-time consolidated tape should cover equities and bonds, delivering data in ‘as close to real-time as technically possible’ after receipt of the data from the different trade venues.
Visual | Why do we need a real-time Consolidated Tape in the EU?
The current lack of quality pre- and post-trade data and the fragmentation of data sources remain an obstacle to the completion of the Capital Markets Union. The benefits of a real-time Consolidated Tape are wide-ranging: from market surveillance for supervisors, to best execution and an improved view on trading opportunities for retail investors, to portfolio management and pre- and post-trade analysis for fund managers to name a few.