We welcome this opportunity to comment on a review of the TV perimeter, and support ESMA’s objective of clarifying when systems and facilities qualify as multilateral.
We welcome this opportunity to comment on a review of the TV perimeter, and support ESMA’s objective of clarifying when systems and facilities qualify as multilateral.
EFAMA places huge importance on this revision of ESMA’s suitability guidelines, as they spell out in detail how investors can invest in sustainable investment products. If they are well designed, the guidelines have the potential to significantly boost capital flows towards sustainable investments; a goal that the European fund industry strongly supports.
The European Fund and Asset Management Association (EFAMA) welcomes the opportunity to respond to this important review of RTS 153/2013 and accompanying guidelines, in light of the procyclicality witnessed during the peak volatility of the Covid crisis. European CCPs already have standard anti-procyclicality tools in their rulebooks and this did lead to less volatile moves in margin in Europe versus other jurisdictions.
With the release of this proposal, the Commission is replicating the OECD / BEPS Inclusive Framework (OECD) Pillar Two Global Anti-Base Erosion (GloBE) Model Rules that came live in December 2021 and addresses how Member States will implement them in a coherent and consistent way across the EU. The work of the Commission and the alignment with the work of the OECD / BEPS Inclusive Framework are to be welcomed.
EFAMA fully supports the Commission’s initiatives to fight tax avoidance and aggressive tax planning. The work of the technical teams that acknowledged our industry’s special requirements and the proposal of carve-out rules to protect investment structures and end-investors are, to a certain extent, to be welcomed.
UCITS equity funds remained in high demand in January, contrary to bond funds
This is evidenced in the second edition of EFAMA's report, "The European Asset Management Industry's Engagement in Financial Education Initiatives", released in March 2022.
The report, prefaced by Commissioner Mairead McGuinness, is divided into three parts.
The fund and asset management industry is a highly regulated industry operating under significant and specific legal, regulatory, transfer pricing and tax frameworks.
Pillar 1: Investment funds are structured as tax neutral investment pooling vehicles as a matter of
public policy.
Pillar 2: The role that investment funds play in providing investors with a diversified portfolio and global market access is essential.
In its support of the development and implementation of the Taxonomy Regulation, EFAMA believes that reporting on the level of alignment with the Taxonomy by non-financial and financial undertakings is essential to strengthening market integrity around sustainability issues.
FIA, ISDA, AFME, ICI, AIMA, EBF and EFAMA (together the Associations) welcome the
European Commission's (the Commission) timely and temporary equivalence decision from
21 September 2020 with respect to UK central counterparties (CCPs) and subsequent
recognition decisions by ESMA of CCPs and the recent temporary equivalence decision for
UK Central Securities Depositories (CSDs) under CSDR. Together, these steps have provided
much needed certainty for continued and uninterrupted access to these CCPs and CSDs by
EFAMA has some concerns with ESMA’s clarifications. In the consultation paper (CP), ESMA seems to have a very broad interpretation of the ‘multilateral systems’ definition under MiFID II and states that ‘systems where trading interests can interact but where the execution of transactions is formally undertaken outside the system still qualify as a multilateral system and should be required to seek authorisation’ (paragraph 36).
We disagree with an extension of its scope to UCITS’ and AIFs’ management companies to the scope of the reporting requirements imposed by MiFIR, Art. 26. This extension would be in breach of the principle of proportionality, as:
Discover the 6 reasons why your organisation should become a member of EFAMA.
Our members enjoy significant benefits including the opportunity to shape the industry positions, get first-hand access to regulatory and political intelligence, engage with industry peers and policymakers, and take part in EFAMA events.
Our three membership categories cater to the wide range of organisations that make up and support the investment management industry in Europe.