As the European trade association representing numerous ETF issuers, EFAMA welcomes the opportunity of this questionnaire to submit a few high-level considerations to the attention of Committee 5 member supervisors. Our inputs are intended to accompany the more detailed submissions of the several European ETF issuers our association represents, in view of informing the Committee’s future work around a possible review of IOSCO’s 2013 Principles for the Regulation of Exchange Traded Funds. Since then, the evolution of the European ETF landscape has largely mirrored that of the larger global market for these products, reaching a total of USD 7.8 trillion in asset under management by the end of January 2021, of which Europe accounted for USD 1.2 trillion.

Our submission is limited to the first main title included under Part A of the Questionnaire, pertaining to the stresses observed for specific types of ETFs during March/April 2020. Here we draw out a number of important “lessons learned” from the most recent and significant volatility episodes of last year, while leaving the answers to the remaining sections of the Questionnaire - related to product structuring, disclosure aspects and liquidity provision - to the more exhaustive responses of our Members and individual ETF issuers.