We welcome this opportunity to comment on a review of the TV perimeter, and support ESMA’s objective of clarifying when systems and facilities qualify as multilateral.
We welcome this opportunity to comment on a review of the TV perimeter, and support ESMA’s objective of clarifying when systems and facilities qualify as multilateral.
EFAMA places huge importance on this revision of ESMA’s suitability guidelines, as they spell out in detail how investors can invest in sustainable investment products. If they are well designed, the guidelines have the potential to significantly boost capital flows towards sustainable investments; a goal that the European fund industry strongly supports.
The European Fund and Asset Management Association (EFAMA) welcomes the opportunity to respond to this important review of RTS 153/2013 and accompanying guidelines, in light of the procyclicality witnessed during the peak volatility of the Covid crisis. European CCPs already have standard anti-procyclicality tools in their rulebooks and this did lead to less volatile moves in margin in Europe versus other jurisdictions.
With the release of this proposal, the Commission is replicating the OECD / BEPS Inclusive Framework (OECD) Pillar Two Global Anti-Base Erosion (GloBE) Model Rules that came live in December 2021 and addresses how Member States will implement them in a coherent and consistent way across the EU. The work of the Commission and the alignment with the work of the OECD / BEPS Inclusive Framework are to be welcomed.
EFAMA fully supports the Commission’s initiatives to fight tax avoidance and aggressive tax planning. The work of the technical teams that acknowledged our industry’s special requirements and the proposal of carve-out rules to protect investment structures and end-investors are, to a certain extent, to be welcomed.
UCITS equity funds remained in high demand in January, contrary to bond funds
This is evidenced in the second edition of EFAMA's report, "The European Asset Management Industry's Engagement in Financial Education Initiatives", released in March 2022.
The report, prefaced by Commissioner Mairead McGuinness, is divided into three parts.
EFAMA welcomes the IOSCO Consultation report which we believe is a good starting point for further engagement with our industry on dilution in Open-Ended Funds (OEFs). We believe that dilution may indeed trigger investor protection concerns for certain funds and welcome, in this respect, IOSCO’s commitment to protect end-investors from material dilution. This being said, we however do not support the consultation report’s significant emphasis on financial stability considerations.
EFAMA welcomes the opportunity of this consultation report to share views on how regulators could foster greater consistency in the management of liquidity risks in the Open-Ended Funds (OEFs) sector and on how the FSB should proceed in the future to evaluate any potential build-up of systemic risks in capital markets.
Environmental, social, and governance (ESG) considerations play a crucial role in asset managers' investment decisions for several reasons:
In July the European Commission released their long-awaited Retail Investment Strategy, including multiple proposals aimed at boosting retail participation in capital markets. EFAMA has provided comments on this in their ‘Have your say’ forum, where we briefly highlight some of our main concerns.
EFAMA responds to ESMA's Consultation Paper - From only 20 ELTIFs at the start of the review of the ELTIF Regulation in late 2021 to 95 as of August 2023, the launch of ELTIF products has significantly increased over the last three years, with further market growth expected in the years to come.
We strongly encourage ESMA to uphold the positive momentum of reforms initiated at Level 1 and guarantee that the requirements established by the draft RTS are conducive to the ongoing success of the ELTIF product.
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