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. 

EFAMA has joined together with the European Sustainable Investment Forum (Eurosif), the Principles for Responsible Investment (PRI), the Institutional Investors Group on Climate Change (IIGCC) and over 90 investors and financial market participants, to call on the European Commission to uphold the integrity and ambition of the first set of European Sustainability Reporting Standards (ESRS).

The draft ESRS Delegated Act presents several potential implications for investors and entails major inconsistencies across the Sustainable Finance legislative framework. In our policy paper we focus on the alignment of ESG reporting on two crucial areas: (1) the requirements of the Sustainable Finance Disclosure Regulation (SFDR), notably the Principal Adverse Impact indicators (PAIs), and (2) the Transition Plans and targets.