EFAMA replied to a specific question on moving to stage 3 for the determination of the liquidity assessment of bonds.
MiFID
The Markets in Financial Instruments Directive governs how funds (and other financial instruments) can be sold and distributed to investors throughout the EU. It does this by balancing investor protection (governing under what rules and conditions investment advice and portfolio management can be given) with providing the right amount of information about products and services (information about the products’ objectives and costs). In most cases, this type of financial advice, which connects funds with end investors, is provided not by fund managers, but by other financial players, such as banks or financial advisers.
Against this backdrop, EFAMA wants to ensure that these rules are balanced and the information provided to investors is meaningful. While more protection is necessary for retail investors, MiFID should allow other, more professional investors, more freedom in defining what information is necessary to conduct their day-to-day business. Also, MiFID must not make it impossible for ordinary EU citizens to access financial advice to save for their future and retirement.
MiFID: EFAMA replies to ESMA consultation on RTS 2 Annual Review
ESMA consults on guidelines of the MIFID II appropriateness and execution-only requirements
EFAMA agrees in principle with many of ESMA’s suggested approaches in their consultation on guidelines on certain aspects of the MIFID II appropriateness and execution-only requirements. However, certain, essential elements still require further considerations before finalising these Guidelines.
EFAMA responds to IOSCO Consultation on Market Data in Secondary Equity Market
EFAMA supports the initiatives launched by IOSCO and other regulators (e.g. ESMA, FCA, SEC) to analyse and address the significant issues concerning market data in the secondary equity market.
MiFIDII/ MiFIR review - EFAMA-BVI-EFSA-NSA priorities
The MiFID/MiFIR review will be key to the future success and competitiveness of the EU's capital markets.
With international competition for investment heating up markedly, European legislators need to ensure that EU regulation is helping, and not hindering, capital market growth and participation.
Various European trade associations representing EU capital markets, including EFAMA, BVI, EFSA and NSA, have published a letter outlining their main priorities for the review. This includes the following core elements:
The availability of a real-time consolidated tape in Europe is critical for the success of the CMU
EFAMA members are paying close attention to the ongoing discussions in the European Parliament and Council to reach a compromise on the MiFID review. Together with a broad majority of market participants, including the sell-side and alternative trading venues, we have consistently made the case for a real-time tape for equities with the inclusion of pre and post-trade data.
EFAMA responses to the discussion questions within the IOSCO report “corporate bond markets – drivers of liquidity during covid-19 induced market stresses”
EFAMA is appreciative of the opportunity to comment on this major IOSCO study on the dynamics of bond market liquidity during market stresses. We provide some detailed responses below, but would reiterate a few high-level points here:
Buy-side use-cases for a real-time consolidated tape
A real-time consolidated tape, provided it is made available at a reasonable cost, will bring many benefits to European capital markets. A complete and consistent view of market-wide prices and trading volumes is necessary for any market, though this is especially true for the EU where trading is fragmented across a large number of trading venues. A real-time consolidated tape should cover equities and bonds, delivering data in ‘as close to real-time as technically possible’ after receipt of the data from the different trade venues.
Visual | Why do we need a real-time Consolidated Tape in the EU?
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.
Investment Funds Distributor Due Diligence Questionnaire
Funds face unique challenges in performing intermediary oversight, and especially so because of MiFID II requirements, changing regulatory landscapes, and the absence of an industry agreed-upon standard between funds and their distribution channels. To help address these challenges, a dedicated working group developed a uniform due diligence questionnaire (DDQ) that will serve as the standard for investment funds (UCITS and AIFs) in performing onboarding and ongoing oversight of distribution channels.