EFAMA and Better Finance hosted a webinar on 23 March 2023 as part of the Global Money Week.
EFAMA has today published its International Quarterly Statistical Release regarding the developments in the worldwide investment fund industry during the fourth quarter of 2022.
EFAMA appreciates the opportunity to comment on the EMIR 3.0 proposal reforming the clearing framework in the EU. We share the objectives of this review which seek to ensure financial stability in the EU, and the well-functioning of the existing central clearing framework. We understand the objective to reduce excessive exposure to substantially systemic CCPs over time, though we maintain that any regulatory measures should be proportionate to the regulatory rationale, and should not unduly harm market participants.
EFAMA has today published its response to the European Commission’s EMIR 3.0 proposal. We support the EC’s goal of increasing the attractiveness of EU central clearing counterparties (CCPs), including simplified product approvals, faster model change authorisations, and greater margin model transparency. A new clearing threshold calculation is also proposed, which further aligns the Clearing Obligation with the rest of the EMIR regulation.
EFAMA has today published its European Quarterly Statistical Release for Q4 2022, together with an overview of the full year 2022.
EFAMA has today published its response to the ESMA consultation on guidelines on funds’ names using ESG or sustainability-related terms. EFAMA members have concerns around the proposed numerical threshold approach as it may not address the underlying greenwashing issues our industry is facing due to the current lack of clarity on many key sustainable finance concepts.
EFAMA welcomes ESMA's consultation paper on guidelines on funds’ names using ESG or sustainability-related terms. We support the overarching objective to promote transparency and tackle the risk of greenwashing by ensuring that investors are protected against unsubstantiated or exaggerated sustainability claims.
EFAMA has today published its latest monthly Investment Fund Industry Fact Sheet, which provides net sales data on UCITS and AIFs for December 2022 at European level and by country of fund domiciliation. A first overview and analysis of the net sales data of UCITS and AIFs over the full year 2022 is also included.
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.
Supervisory convergence is a core element of the Single Market and integral to removing barriers to cross-border provision of financial services. It is not enough to have a common rule book, but also the reading of those rules by supervisors and supervisory practices should converge to ensure the Single Market is not hampered by diverging interpretations and gold-plating of EU rules.
• EFAMA reiterates the European asset management industry’s strong support for the CMU project in all its dimensions. We welcome the range of initiatives, from the overarching aim of rebuilding confidence in financial markets by putting investors’ interests at the heart of the project, to the promotion of market-based financing of the economy, the development of a PEPP or the development of a comprehensive strategy on sustainable finance.
EFAMA is grateful for the opportunity to comment on the new OECD Public Discussion Draft on BEPS Action 6 and the treaty entitlement of non-CIV funds Discussion Draft on non-CIV examples. In addition EFAMA would like to make positive use of this opportunity and comment as well on the general situation of CIVs as well as of Non-CIVs against the background of the BEPS Action 6 implementation.
EFAMA welcomes the opportunity to respond to the EBA on its proposal for a new prudential regime for investment firms. As the EBA is aware, the activity of portfolio management on behalf of thirdparty clients broadly falls under three separate EU legal regimes:
i. Individual discretionary portfolio management performed by investment firms on a client-byclient basis, authorised under and complying with the Markets in Financial Instruments Directive, as per Annex I Section A, point 4 (as recently amended by MiFID II);
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