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

Press Release

Distribution ＆ Client Disclosures

PRIIPs

22 October 2021

EFAMA Statement on the ECON Committee’s draft report amending the UCITS directive for PRIIPs

Andreas Stepnitzka, EFAMA Deputy Director, Regulatory Policy, comments:

Policy Position

Distribution ＆ Client Disclosures

Management Companies

29 September 2021

Distance marketing of consumer financial services – Review of EU rules

EFAMA provided high-level comments to the Commission’s consultation on the potential review of the Directive on Distance Marketing of Consumer Financial Services.

We agree with the Commission’s interpretation that the Directive is seen as a “safety net” for financial services not already subject to product-specific legislation. Fund and asset managers are already subject to various, more stringent and detailed sectoral legislations, such as (but not limited to) UCITS, AIFMD and MiFID as well as the (more recent) Cross-Border Fund Distribution Directives.

Policy position

Distribution ＆ Client Disclosures

PRIIPs

09 September 2021

Joint industry response to the EC Better Regulation consultation on the UCITS ‘quick fixes'

The European Commission recently adopted amendments to the Packaged Retail and Insurance-based Investment Products (PRIIPs) Regulation and the Undertakings for Collective Investment in Transferable Securities (UCITS) Directive. However, in contrast to earlier plans, the adoption of the revised Regulatory Technical Standards (RTS) amending Commission Delegated Regulation (EU) 2017/653 has been postponed.

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.

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Related publications

Publication

MIFID

Distribution ＆ Client Disclosures

PRIIPs

Management Companies

AIFMD

03 June 2020

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.

Publication