Andreas Stepnitzka, EFAMA Deputy Director, Regulatory Policy, comments:
Andreas Stepnitzka, EFAMA Deputy Director, Regulatory Policy, comments:
EFAMA has today published its latest monthly Investment Fund Industry Fact Sheet, which provides net sales data on UCITS, and AIFs sold in August 2021, at European level and by country of fund domiciliation.
The Commission aims to present a legislative proposal to address the tax-induced debt-equity bias, also to support the action plan for the Capital Markets Union and to encourage companies to finance their investment through equity contributions rather than through debt financing.
“Oliver Wyman’s study ‘Caught on Tape’ provides a perplexing take on Consolidated Tape for Europe. Sure enough, it starts with accurate observations: the high number of trading venues in Europe, the resultant fragmented liquidity, unseen liquidity due to the lack of a consolidated tape, and the fact that leading markets like the US and Canada today benefit from a real time consolidated tape.
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.
EFAMA has been at the forefront of efforts to urge authorities to raise financial literacy levels in the general population through widespread and improved financial and investor education initiatives. We are also a long-time supporter of IOSCO's World Investor Week and organise a yearly event on investor education.
The old-age dependency ratio in the EU continues to increase; Eurostat’s recent figures project that by 2050, there will be fewer than 2 working-age adults for each person aged 65 or older, versus just under 3 today.
Investor education initiatives are essential to improve financial literacy and empower citizens to make sound decisions when managing their savings. If citizens do not have the basic knowledge to understand financial concepts such as risk diversification, compound interest and real rate of return, they won’t know where to start or what to ask should they wish to invest their savings. A lack of sufficient financial literacy in most European countries helps explain why the vast majority of households don’t directly invest any of their savings in the capital markets.
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.
EFAMA welcomes the opportunity to respond to the EC’s targeted consultation on the EU’s central clearing framework. We are pleased to find in this consultation document a fair reflection of the complexity of the CCP ecosystem and consistency with the issues raised in previous dialogues held with the European Commission. In that same spirit, we hope in our response to provide feedback that resonates with the EC’s broader policy objectives while minimizing systemic risk and undue harm to our industry.
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.
EFAMA appreciates the opportunity to share our views on the European Commission’s consultation on enhancements to the suitability and appropriateness assessments forming part of the wider, upcoming Retail Investment Strategy.
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