EFAMA wholeheartedly supports ESMA’s objective of ensuring a consistent and harmonised application of the MiFID II product governance requirements. In our response to their consultation on the topic, we raised the following points: 

EFAMA welcomes the European Securities and Market Authority’s continuous commitment to creating a single market for investment funds, confirmed by the draft regulatory standards currently under consideration. These RTS/ITS would further harmonise information that asset managers should provide to their national competent authorities before marketing or managing an investment fund on a cross-border basis, thus facilitating intra-EU product distribution.

EFAMA welcomes the OECD's work on Schedule C: Exclusion of Revenues and profits from Regulated Financial Services from the scope of Pillar One, in particular the amendments to the definition of “Asset Manager", licensing asset management as a business, the level of regulaton and the activities list. 

EFAMA shares the urgent need to improve the consistency and comparability of sustainability reporting at a global level. Therefore, we welcome the opportunity to respond to the ISSB consultation on the Exposure Drafts on “General Requirements for Disclosure of Sustainability Related Financial Information” (IFRS S1) and on “Climate-Related Disclosures” (IFRS S2).