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
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FSB consultation on policy proposals to enhance Money Market Funds' resilience
While cognisant of the FSB’s strict timelines in view of upcoming G20 summits, these should not come at the expense of a necessary and more informed debate on the causes at the root of last year’s stresses in global short-term funding markets (STFMs) and on ways to remedy these in the future. In fact, the options presented in the consultation report appear hurried and dismissive of critical facts, calling therefore for a deeper engagement with the global financial and investing community at large.
EFAMA responds to IOSCO's recommendations on sustainability-related practices policies, procedures and disclosures in asset management
EFAMA welcomes IOSCO's enhanced attention to transparency efforts supporting informed and qualified investment decisions in sustainability-related products. We support the adoption of such recommendations at the international level and believe IOSCO should leverage the experience with SFDR and Taxonomy in Europe to help establish consistent international standards, definitions and best practices.
In this response, we would like to highlight three pressing challenges deserving greater attention in the report from asset managers' perspective.