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).

EFAMA strongly supports the initiative carried out by EFRAG with the publication of the Exposure Drafts on the European Sustainability Reporting Standards (ESRS). The Exposure Drafts provide key elements framing the architecture of reporting requirements and clarifying the content and key concepts of CSRD. The resulting data will be of crucial importance for investors and for achieving the EU objective to transition towards a zero emissions economy by 2050. 

EFAMA supports the Commission’s efforts to encourage more companies to finance their investment through equity contributions rather than debt financing.

The Commission decided to follow a policy option that will enable the deductibility of an allowance on equity financing costs complemented by a rule to limit the deductibility of interest on debt financing instruments.

EFAMA is appreciative of the opportunity to comment on this major IOSCO study on the dynamics of bond market liquidity during market stresses.  We provide some detailed responses below, but would reiterate a few high-level points here:

EFAMA appreciates the opportunity to comment on the European Commission's Targeted consultation on open finance framework and data sharing in the financial sector.

The industry welcomes the fact that IOSCO’s 2013 Principles remain relevant and appropriate and that no important gaps in the Principles have been identified. In the consultation report, we are pleased to see the resilience of the ETF structure being recognised, despite the severity of the March 2020 market correction and of more recent episodes, concluding that no ETF-specific structural issues have been identified as a cause for regulatory concern.