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.

EFAMA is grateful for the opportunity to contribute to the drafting of the Regulation through a consultation and we appreciate the effort of the regulator to adopt an approach to reporting consistent with EMIR and to develop, where more efficient, a different reporting logic.

EFAMA and its Members appreciate the opportunity to comment on the second FSB/IOSCO consultative document in the context of the current global debate around the alleged “systemic” nature of the asset management industry. EFAMA is the representative association for the European investment management industry. We represent through our 26 national association members, 63 corporate members and 25 associate members about EUR 17 trillion in assets under management, of which EUR 11.3 trillion managed by 55,600 investment funds at end‐December 2014.