We appreciate the opportunity to respond to this important consultation and remain gladly at the disposal of the European Commission staff to elaborate on any of our responses.
Capital markets
Investment managers, acting on behalf of their retail and institutional clients, are among the largest investors in financial markets. They represent a key component of the market’s “buy-side” segment.
In representing the interests of its members on wholesale capital market issues, EFAMA advocates for fair, deep, liquid, and transparent capital markets, supported by properly regulated and supervised market infrastructure.
EFAMA Position on the draft Joint Guidelines of ESAs regarding customer due diligence under Anti-Money Laundering Directive
EFAMA is closely monitoring the recent regulatory developments in the field of anti-money laundering and counter-terrorist financing, in particular the due diligence duties of the asset management sector. EFAMA is embracing the objective of enhancing transparency and accessibility to the beneficial ownership information and also fully acknowledges the importance of obtaining accurate identification and verification data of natural and legal persons for fighting money laundering and terrorist financing.
EFAMA's reply to ESMA's CP on RTS specifying the scope of the consolidated tape for non-equity financial instruments
EFAMA supports every efforts made to enhance financial markets regulation which reinforces the stability and the transparency of the financial system.
In that perspective, EFAMA welcomes the opportunity to comment on the ESMA Consultation Paper on RTS specifying the scope of the consolidated tape for non-equity financial instruments. We consider that a consolidate tape (“CT”) is a key positive factor for price formation and transparency.
Prior to replying to the consultation, we wish to make the following general remarks
EU Equity Consolidated Tape Proposal - Statement of Principles
A Cross-Industry Consensus on the EU Equity Consolidated Tape Proposal - Statement of Principles
EFAMA, AFME, BVI and Cboe agreed on a set of 11 Principles.
The provision of an appropriately constructed EU Equities Consolidated Tape (“CT”) will democratise access to equities (as proposed by the EU Commission) for all investors, regardless of resources or sophistication, with a comprehensive and standardised view of EU equities prices.
EFAMA’s reply to ESMA’s consultation paper on the opinion on Trading Venue Perimeter
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 views and recommendations on ESMA's consultation on the review of EMIR RTS on APC margin measures
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.
Closet Index Funds
EFAMA has reviewed ESMA’s statement “Supervisory work on potential index tracking”, which sets out research to determine whether any indication of closet indexing could be found at EU level. To contribute to the debate on this matter, EFAMA has prepared a paper, which highlights the limits of identifying closet index funds through a statistical analysis, drawing on recently published research papers.