EFAMA firstly wishes to commend the FSB’s change of focus in the course of 2015, from a proposed assessment methodology intended to identify non-bank, non-insurance globally systemically important financial institutions (NBNI G-SIFIs) to a revised and more objective focus on asset management activities. Although we understand the former framework may be revisited by the FSB once its Recommendations are finalised, we appreciate that certain key characteristics of the asset management industry have been recognised and well reflected in the present consultative document.
International Agenda
Whereas EFAMA’s primary focus is on EU financial services legislation, we also actively engage at a global level with international standard-setting bodies, such as IOSCO (of which EFAMA is an affiliate member), the Financial Stability Board (FSB) or the OECD, to name but a few. In this context, EFAMA strongly supports the development of mutually agreed international regulatory standards to reduce market fragmentation and facilitate cross-border business.
We also keep a close watch on regulatory developments in jurisdictions outside the European Union that are likely to significantly impact our members’ activities. For example, in recent years EFAMA actively engaged with foreign authorities on regulations limiting the distribution of European funds abroad. Examples include filings to the UAE Securities and Commodities Authority (SCA), the Indian SEBI, the U.S. SEC and the OECD.
EFAMA reply to FSB consultation on proposed policy recommendations to address structural vulnerabilities from asset management activities
IOSCO Consultation Report on anti-dilution liquidity management tools
EFAMA welcomes the IOSCO Consultation report which we believe is a good starting point for further engagement with our industry on dilution in Open-Ended Funds (OEFs). We believe that dilution may indeed trigger investor protection concerns for certain funds and welcome, in this respect, IOSCO’s commitment to protect end-investors from material dilution. This being said, we however do not support the consultation report’s significant emphasis on financial stability considerations.
FSB Consultation Report on addressing vulnerabilities from liquidity mismatch in open-ended funds
EFAMA welcomes the opportunity of this consultation report to share views on how regulators could foster greater consistency in the management of liquidity risks in the Open-Ended Funds (OEFs) sector and on how the FSB should proceed in the future to evaluate any potential build-up of systemic risks in capital markets.
EFAMA replied to the OECD Pillar One – Amount A: Regulated Financial Services Exclusion public consultation
EFAMA replied to the OECD Pillar One – Amount A: Regulated Financial Services Exclusion public consultation. Aiming to change the views of those members of the OECD/IF that still maintain that asset managers should not be excluded from Amount A.
In this comment paper, EFAMA is taking the opportunity to: