Distribution & Client Disclosures

EFAMA monitors issues surrounding fund distribution and disclosures to investors. These include investor protection and disclosure issues arising from the evolving PRIIPs and MiFID frameworks, the shift towards digital distribution tools, and the continued integration of ESG considerations into fund products.

Related policy positions

Policy Position

Distribution ＆ Client Disclosures

22 March 2022

EFAMA's response to the EU Commission's targeted consultation on options to enhance the suitability and appropriateness assessments

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.

Policy position

Distribution ＆ Client Disclosures

PRIIPs

15 December 2021

EFAMA response to ESA’s Joint Committee call for evidence on PRIIPs

EFAMA continues to support the overarching aim of the PRIIP KID as a single pre-disclosure document for all types of investment products.

EFAMA believes that the ESAs Joint Call for Evidence on PRIIPs and any subsequent proposals for revision of the PRIIPs Regulation should come after assessing in practice the revised PRIIPs RTS to be implemented from 31 December 2022, both to retail AIFs and UCITS.

Press Release

Distribution ＆ Client Disclosures

PRIIPs

24 November 2021

European Parliament votes on ‘quick fixes’ for PRIIPs and UCITS - EFAMA statement

We welcome yesterday's vote by the European Parliament plenary formally adopting two ‘quick fixes’ for PRIIPs (Packaged retail investments and insurance-based products) and UCITS (Undertakings for Collective Investment in Transferable Securities).

ESMA’s Consultation paper on the review of the guidelines on MiFID II product governance requirements

EFAMA wholeheartedly supports ESMA’s objective of ensuring a consistent and harmonised application of the MiFID II product governance requirements. In our response to their consultation on the topic, we raised the following points:

Policy Position

Distribution ＆ Client Disclosures

Retail Investment

07 July 2022

EU Commission targeted consultation on open finance framework and Data sharing in the financial sector

EFAMA appreciates the opportunity to comment on the European Commission's Targeted consultation on open finance framework and data sharing in the financial sector.

Policy Position

EFAMA response to EC CfE ESG ratings and sustainability risks in credit ratings

Distribution ＆ Client Disclosures

Sustainable Finance

EU Taxonomy

Sustainability-related Disclosures (SFDR)

13 June 2022

EFAMA response to EC CfE ESG ratings and sustainability risks in credit ratings

EFAMA welcomes the opportunity to respond to the EC’s targeted consultation on the functioning of the ESG rating market in the EU and on the consideration of ESG factors in credit ratings. Please note that our response covers, at the same time, ESG ratings and ESG data providers, as the demand for ESG “raw” data has been increasing at a steady pace. The use of ESG data has also rapidly shifted from a narrow set of investment products to being prolific across all investment products.