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