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.
The revised ELTIF – a long-term opportunity for European investors
EFAMA firmly supports the European Commission’s proposal to revise the European Long-Term Investment Fund (ELTIF) Regulation. The revised framework has the potential to transform ELTIF into a product of choice for European investors and to become a cornerstone of the Capital Markets Union.
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- the Competitiveness of our industry
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Fund managers retain only 41% of the total cost paid by retail investors | Market Insights | Issue #6
EFAMA has released its latest Market Insights report titled “Perspective on the costs of UCITS”. The full report breaks down the costs of UCITS, focusing on the fees charged for the different services provided along the investment fund value chain and distinguishing between the product cost for which fund managers are directly responsible, and the
Annual Review 2018-2019
I am pleased to provide you with an overview of our activities since our 2018 Annual General Meeting in Cyprus.
Credit where credit is due. I would like to congratulate my predecessor Peter De Proft for all the work in his twelve year tenure as EFAMA Director General and for the constructive support he has shown me from the start. This has greatly facilitated the handover.
Ownership of Investment Funds in Europe
The report provides a wealth of facts and figures on the evolution of holdings of financial assets and investment funds among European investors in recent years. It aims to answer three main questions: