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.
EFAMA welcomes the decision of the Commission to review the prospectus regime with the objective to make it easier and simpler for companies generally and in particular SMEs in Europe to access capital markets, to provide all types of issuers with further simplification and flexibity and to ensure adequate information for investors.
EFAMA believes that the general assessment of the characteristics of automated financial advice tools is captured accurately.
The signatories share the following views:
• Securitisation is an important element of well-functioning financial markets. Prudently deployed and sensibly regulated, it can:
o act as a bridge between the banks’ financing and the capital markets;
o enable non-banks to diversify funding sources; and
o provide investors with high quality fixed income securities at attractive yields.
EFAMA is supportive of the general objectives of the PRIIP KID Regulation. We are however concerned about the very limited time that product manufacturers will have between the final technical rules (RTS) and essential guidelines being published and the deadline to produce Key Information Documents (KIDs) from 31 December 2016 onwards. Having provided extensive feedback throughout the ongoing Level-2 work, we seriously doubt there will be enough time for market participants to implement the final rules by the end of this year, as originally foreseen by the co-legislators.
EFAMA welcomes the opportunity to provide the views of the asset management industry to this challenging exercise of assessing the impacts of recent regulatory reforms in the area of financial services.
There are a number of general remarks that we would like to make by way of introduction.
Need for consistency and coordination
After having looked extensively at the Level-2 work done by the ESAs, EFAMA1 comes to the unfortunate conclusion that, due to the very technical nature of the underlying methodologies and calculations, there will not be enough time for market participants to fully implement the PRIIP KID by 31 December 2016.
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