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

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.

Policy Position

Distribution ＆ Client Disclosures

Retail Investment

24 May 2022

IOSCO Retail Market Conduct Task Force Report

EFAMA appreciates the opportunity to respond to the IOSCO Retail Market Conduct Task Force's consultation on retail investment trends.

In our view, the IOSCO report provides a comprehensive picture of the retail market trends and risk magnifiers.

We also take the opportunity to share our views on the following areas:

Policy Position

Distribution ＆ Client Disclosures

27 April 2022

EFAMA response to ESMA’S consultation paper “guidelines on certain aspects of the Mifid II Suitability Requirements”

EFAMA places huge importance on this revision of ESMA’s suitability guidelines, as they spell out in detail how investors can invest in sustainable investment products. If they are well designed, the guidelines have the potential to significantly boost capital flows towards sustainable investments; a goal that the European fund industry strongly supports.

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.

Press Release

Distribution ＆ Client Disclosures

PRIIPs

09 September 2021

Industry calls for reasonable implementation timeline for PRIIPs changes

EFAMA and several other financial industry associations, raised concerns in response to a consultation conducted by the European Commission on planned changes to the Packaged Retail and Insurance-based Investment Products (PRIIPs) framework.

The unexpected delay to the adoption of the revised PRIIPs RTS cuts the implementation period for the industry by more than two months. This leaves PRIIPs manufacturers and distributors with a too short period instead of the original timeframe of 12 months to implement the new rules.

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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