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 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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