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 welcomes the decision of the European Commission to adopt a targeted approach in its review of the Alternative Investment Fund Management Directive (AIFMD), along with key harmonising provisions within the Undertakings for Collective Investment in Transferrable Securities Directive (UCITSD). This focus on targeted improvements recognises the role this framework has played in encouraging the growth in the European Alternative Investment Fund (AIF) market over the past decade and its resilience even throughout recent market stresses.
EFAMA strongly supports the Commission's draft proposal amending the ELTIF Regulation where it addresses some of the major obstacles that have undermined the attractiveness of the ELTIF product since inception. The revised legal framework has the potential to transform ELTIF into a product of choice for a larger (retail) investor audience, all while serving the purposes of the Capital Markets Union (CMU). However, some important adjustments remain to be made for the ELTIF regime to reach its full potential as a competitive long-term investment option.
The European Commission’s proposal on MiFIR establishes the blueprint for a consolidated tape (CT) for Europe’s capital markets. It also significantly alters the competitive market structure brought about by MiFID II by introducing greater transparency requirements. Finally, it addresses important issues around market data costs.
EFAMA replied to IASB’s request for information on the Post-Implementation Review (PIR) of IFRS 9 – Classification and measurement. Our paper recaps EFAMA’s key concerns and recommendations to the IASB. The key concerns of the industry are the removal of recycling (in particular for institutional investors) and the classification of investment entities and investment funds as debt instruments.
We commend the work that IOSCO has undertaken to date on this topic including the survey work and the summary findings in the form of the report currently under review. It is fair to say that the conclusions of the report and areas for further work gave rise to detailed discussions within our industry, yielding ultimately firm views on the priority areas that we support and see value in, and areas we felt were not reflected in the study and thereby building risk into margining models in future crisis scenarios. These areas are fur
For asset managers the main issue continues to be the reclassification of ETDs as OTCs as a result of the non-equivalence of UK regulated markets. While we understand that a review is legally mandated at this point in time, we do not see value in recalibrating the various thresholds or making changes to the calculation methodologies unless these are in the two areas we define below. Our main concern revolves around the fact that changes would carry significant compliance costs while making little impact on the population of counterparties and notional captured by the thresholds.
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