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.
Policy
EFAMA High-Level Response to IOSCO Questionnaire on ETFs for industry participants
EFAMA responds to IOSCO Consultation on Market Data in Secondary Equity Market
EFAMA supports the initiatives launched by IOSCO and other regulators (e.g. ESMA, FCA, SEC) to analyse and address the significant issues concerning market data in the secondary equity market.
EFAMA reply to ESMA CP on marketing communications guidelines
EFAMA believes that ESMA’s draft ‘marketing communication’ Guidelines still require important clarifications to ensure full alignment between them and MiFID II’s Commission Delegated Regulation Article 44. This alignment is essential to ensure coherent rules for fund management companies and distributors. Unfortunately, parts of the proposed Guidelines are overly prescriptive and may unintentionally make some marketing materials vaguer or even inconsistent with local MiFID requirements for distributors.
EFAMA response to EC consultation on Sustainable Corporate Governance
Investors would benefit from an EU legal framework with due diligence guidelines and reporting requirements for companies in the real economy. This framework should be consistent with the reporting requirements in the revised NFRD and the disclosures in the Sustainability-Related Disclosures regulation (SFDR). At the same time, any framework for supply chain due diligence should not impose a competitive disadvantage for EU companies.