Ever since the term “shadow banking” has emerged from the FSB’s working circles in the immediate aftermath of the 2008 global financial crisis[1], our association has consistently argued that its use as a reference to regulated asset management companies and their funds is inaccurate and mis-leading.
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.
EFAMA's response to the EBA consultation on draft RTS criteria for the identification of shadow banking entities
Distance marketing of consumer financial services – Review of EU rules
EFAMA provided high-level comments to the Commission’s consultation on the potential review of the Directive on Distance Marketing of Consumer Financial Services.
We agree with the Commission’s interpretation that the Directive is seen as a “safety net” for financial services not already subject to product-specific legislation. Fund and asset managers are already subject to various, more stringent and detailed sectoral legislations, such as (but not limited to) UCITS, AIFMD and MiFID as well as the (more recent) Cross-Border Fund Distribution Directives.
EU retail investments: comprehensive strategy to increase retail investor participation required
EFAMA wholeheartedly supports a retail investment strategy that gives EU citizens the necessary tools and the confidence to put their savings to work by investing in capital markets.
EFAMA reacts to IOSCO statement on liquidity risk management for investment funds
EFAMA welcomes the recent statement by Ashley Alder, IOSCO Board Chair, on liquidity risk management for investment funds.
Liquidity and counterparty risks in ETFs
EFAMA recently finalised a Comment Paper in response to the ECBs November 2018 findings around liquidity and counterparty risks in ETFs, included in the ECBs semi-annual Financial Stability Review.
EFAMA welcomes final agreement on legislation facilitating cross-border distribution of funds
We welcome yesterday's vote by the European Parliament plenary, formally adopting the trilogue agreement on the Commission's initiative to remove cross-border barriers to the distribution of investment funds.
This marks a decisive recognition of the need to postpone the application of the PRIIPs disclosure regime for UCITS by two years, in light of the regime's documented shortcomings. It also allows the European Commission more time to conduct a thorough review of the same within one year.