EFAMA agrees with the FSB that market participants should integrate the management of margin and collateral calls into their risk management, governance, and operational processes.
Management Companies
EFAMA has been looking at legislative proposals with a direct impact on asset management companies and services, and closely follows any regulatory developments of critical importance to the sector. In addition to issues related to risk management and financial stability, high up on the agenda of EFAMA members is the framework for a prudential regime for Investment Firms (IFD/R), and related implementing measures directly descending from such framework.
EFAMA is focused on minimising the impact of the rules on asset management companies, in particular those holding a limited MiFID license. Key to the sector is the need for proportionality, especially firms that are not authorised to hold client money/securities, or to deal on their own account.
FSB consultation on liquidity preparedness for margin calls in non-bank financial intermediation
Tweaking the AIFMD/UCITS Framework
EFAMA welcomes the decision of the European Commission to adopt a targeted approach in its review of the Alternative Investment Fund Management Directive (AIFMD), along with key harmonising provisions within the Undertakings for Collective Investment in Transferrable Securities Directive (UCITSD). This focus on targeted improvements recognises the role this framework has played in encouraging the growth in the European Alternative Investment Fund (AIF) market over the past decade and its resilience even throughout recent market stresses.
FATF Consultation on Recommendation 24
EFAMA welcomes the work of the FATF in reviewing and reinforcing its existing recommendations to ensure that these remain fit for purpose in tackling global financial crime.
ESMA Consultation paper on Guidelines on Liquidity Management Tools of UCITS and open-ended AIFs
ESMA Consultation paper on Draft RTS on Liquidity Management Tools under the AIFMD and UCITS Directive
EBA & ESMA discussion paper on the Commission’s call for advice on the prudential framework for investment firms
Annual Report 2016
Asset Management Report 2017
Closet Index Funds
EFAMA has reviewed ESMA’s statement “Supervisory work on potential index tracking”, which sets out research to determine whether any indication of closet indexing could be found at EU level. To contribute to the debate on this matter, EFAMA has prepared a paper, which highlights the limits of identifying closet index funds through a statistical analysis, drawing on recently published research papers.