EFAMA firmly supports the Commission’s proposed amend of the ELTIF Regulation, in line with its recently revamped “new” CMU.

- Asset managers represent an important group of benchmarks’ users. In this context, EURIBOR rate is used by investment funds across all kinds of asset classes and financial instruments, as well as a benchmark for measuring fund performance, driving fee calculations and determining asset allocation.

- The identification of fallback rates for the contract with reference to EURIBOR are essential for asset managers and a stable and permanent approach would make the fallback clauses more robust and ensure further transparency. 

EFAMA welcomes this ESMA initiative and we agree with the conclusions in the ESMA Report that there is an overall need to strengthen the laws applicable to data in connection with the MiFIDII/MiFIR Review, aside the implementation of a Consolidated Tape .  We consider that the draft Guidelines will further strengthen the MiFID level 1 and level 2 measures and will foster the establishment of a cost-based approach for market data procurement. Therefore, we would be in favour of turning the proposed guidelines into binding regulation.

The AIFMD is one of the pillars of EU regulation for asset managers and investment funds, which have a crucial role to play in the development of the Capital Markets Union (CMU) and the post Covid-19 economic recovery in the EU.