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.
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.
Our corporate members are both subsidiaries of an EEA parent that is a credit institution as per Article 4(1)(1) of the CRR, or stand-alone investment firms as per Article 4(1)(2) of the CRR. Both types of entities risk becoming subject to the Maximum Ratio Rule as asset management companies licensed under either a UCITS or AIFM management company license, or licensed as investment firms under the MiFID regime to provide discretionary portfolio management services on a client-by-client basis.
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