EFAMA welcomes ESMA’s Call for Evidence on asset segregation and custody services as a precious occasion to confirm our previous key messages - as per our response to the previous consultation around Guidelines on asset segregation under the AIFMD of December 2014 – and to clarify our position on new aspects of ESMA’s work.
EU Fund regulation
The EU fund product landscape is deep, diverse and dynamic. Since the birth of the UCITS framework in 1985, European institutions have progressively refined it into a global “gold standard”, one that successfully balances strict regulatory requirements with the flexibility required by manager to meet evolving client demands. The successful evolution of UCITS was followed by the creation of alternative investment funds (AIFs) under the 2011 AIFM Directive, adding a second important pillar to EU fund/manager regulation. Building on this second pillar are further ambitious EU fund products, such as EUSEFs, EUVECAs and ELTIFs. EFAMA has helped guide all of these key regulatory developments, informing policymakers and regulators on their main merits and drawbacks, while also keeping a close eye on their respective review initiatives.
EFAMA strongly supports a fundamental review to the ELTIF regime, in view of broadening its eligible investment universe and adapting it to better meet retail investor needs. We are also closely monitoring the review of the AIFM Directive from a product regulation standpoint, including possible spillover effects on the UCITS Directive requirements. Further work involves keeping pace with relevant ESMA initiatives, such as the work around the Common Supervisory Action on costs and fees for UCITS.
EFAMA response to ESMA Call for Evidence on asset segregation
EFAMA response to Green Paper on Retail Financial Services
EFAMA welcomes the opportunity to respond to the European Commission’s Green Paper on retail financial services. Widening the opportunities for European citizens to save and invest will facilitate better outcomes both for savers and the wider European economy.
EFAMA fully shares the goals of a Single Market for retail financial services in the EU, i.e.:
1. Promoting an EU-wide market in retail financial services that can facilitate cross-border business and consumer choice.
EFAMA response to EC consultation on impacts of maximum remuneration ratio under CRD IV
Our corporate members are both subsidiaries of an EEA parent that is a credit institution as per Article 4(1)(1) of the CRR, or stand-alone investment firms as per Article 4(1)(2) of the CRR. Both types of entities risk becoming subject to the Maximum Ratio Rule as asset management companies licensed under either a UCITS or AIFM management company license, or licensed as investment firms under the MiFID regime to provide discretionary portfolio management services on a client-by-client basis.
EFAMA reacts to IOSCO statement on liquidity risk management for investment funds
EFAMA welcomes the recent statement by Ashley Alder, IOSCO Board Chair, on liquidity risk management for investment funds.
Liquidity and counterparty risks in ETFs
EFAMA recently finalised a Comment Paper in response to the ECBs November 2018 findings around liquidity and counterparty risks in ETFs, included in the ECBs semi-annual Financial Stability Review.
EFAMA welcomes final agreement on legislation facilitating cross-border distribution of funds
We welcome yesterday's vote by the European Parliament plenary, formally adopting the trilogue agreement on the Commission's initiative to remove cross-border barriers to the distribution of investment funds.
This marks a decisive recognition of the need to postpone the application of the PRIIPs disclosure regime for UCITS by two years, in light of the regime's documented shortcomings. It also allows the European Commission more time to conduct a thorough review of the same within one year.
Asset Management in Europe - An Overview of the Asset Management Industry - November 2020
The report aims to provide a unique and comprehensive set of facts and figures on the state of the industry at the end of 2018 but also to highlight the fundamental role of asset managers in the financial system and wider economy.
European MMFs in the Covid-19 market turmoil: Evidence, experience and tentative considerations around eventual future reforms
The pandemic-induced market events experienced in March 2020 have marked the first true ‘stress-test’ for European MMFs, following the introduction of the EU Money Market Fund Regulation (MMFR) in 2017. Despite the severity of the liquidity stress in the secondary market for short-term instruments and the significant outflows experienced by European MMFs across all three of the MMFR-identified categories (public debt CNAV, LVNAV and VNAV), funds proved resilient.
Demystifying ETPs: an EFAMA guide for the European investor
Through its ETF Task Force, EFAMA has produced an Investor Education Guide intended to draw out, in a simple form, the defining features for the three main types of ETPs (Exchange-traded products) listed across European markets. The association hopes this guide will primarily assist investors in having a clearer understanding of different ETPs and help investors appreciate the differences between them, especially from a risk and product complexity viewpoint.