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 Response to the IOSCO Consultation on CIS Liquidity Risk Management Recommendations (CR04/2017)
Use of Leverage in Investment Funds in Europe | AMIC-EFAMA Joint Paper
EFAMA response to the IOSCO Consultation on Termination of Investment Funds
EFAMA welcomes the opportunity to provide its comments on the Good Practices to be adopted by IOSCO for the Termination of Investment Funds. We agree that the decision to terminate a fund can have significant impact on investors in terms of the costs associated with such an action, or the ability for investors to redeem their holdings during the termination process. In this regard, even in the context of a fund’s voluntary termination, asset managers must abide by their fiduciary obligation to act in the best interest of their investors.
EFAMA's response to the EBA consultation on draft RTS criteria for the identification of shadow banking entities
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.
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.
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.
