EFAMA offers a detailed view on the active accounts proposal in this paper. Costs to the end investor are broken down into two main buckets i) operational build-out and ii) in nominal terms the much larger impact of loss of netting efficiencies. Potential impacts on financial stability are also examined, with a focus on the widening basis which will result from large volumes of one-directional flows onto an EU-CCP. The impact on margins and procyclicality are also studied. The analysis points to increased liquidity risk for
Policy
Latest positions
Policy Topics
Policy Position
Pensions
26 May 2023
Response to EIOPA on technical advice for the review of the IORP II Directive
EFAMA believes that IORPs should be able to invest in financial instruments traded in all third country markets where the latter meet certain conditions, regardless of the adoption of an equivalence decision by the Commission (...).
Policy position
Benchmarks
05 May 2023
European Commission call for evidence on the review of the scope and regime for non-EU Benchmarks
EFAMA welcomes the opportunity to respond to the European Commission’s Call for Evidence on the ‘Review of the scope and third-country regime of the Benchmark Regulation.’
Policy position
Benchmarks
05 May 2023
EFAMA high-level views on the European Commission revision on the regime applicable to the use of Benchmarks administrated in a third country
Following the EFAMA's partial response to the European Commission's targeted consultation on the regime applicable to the use of benchmarks administered in a third country, we would like to make additional comments on the ongoing review of the regime.
