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.

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.