EFAMA replied to a specific question on moving to stage 3 for the determination of the liquidity assessment of bonds.
Capital markets
Investment managers, acting on behalf of their retail and institutional clients, are among the largest investors in financial markets. They represent a key component of the market’s “buy-side” segment.
In representing the interests of its members on wholesale capital market issues, EFAMA advocates for fair, deep, liquid, and transparent capital markets, supported by properly regulated and supervised market infrastructure.
MiFID: EFAMA replies to ESMA consultation on RTS 2 Annual Review
ESMA consults on guidelines of the MIFID II appropriateness and execution-only requirements
EFAMA agrees in principle with many of ESMA’s suggested approaches in their consultation on guidelines on certain aspects of the MIFID II appropriateness and execution-only requirements. However, certain, essential elements still require further considerations before finalising these Guidelines.
Joint trade association letter regarding Implementation of CSDR SDR
On 11 March 2021, EFAMA and 14 trade associations representing a wide range of stakeholders in the European and global financial markets wrote to the European Commission and ESMA raising concerns about the implementation of the mandatory buy-in requirement under the EU’s CSDR Settlement Discipline Regime.
Cross-Industry Consensus on EU Equity Consolidated Tape
EFAMA, AFME, BVI and Cboe Europe Agree Cross-Industry Consensus on EU Equity Consolidated Tape
Monday 30 May, 2022 - AFME, BVI, Cboe Europe and EFAMA have today jointly published a position paper which provides a set of key principles needed to ensure the successful creation of an EU Equity Consolidated Tape (CT).
EFAMA’s reply to ESMA’s consultation paper on the opinion on Trading Venue Perimeter
We welcome this opportunity to comment on a review of the TV perimeter, and support ESMA’s objective of clarifying when systems and facilities qualify as multilateral.
EFAMA views and recommendations on ESMA's consultation on the review of EMIR RTS on APC margin measures
The European Fund and Asset Management Association (EFAMA) welcomes the opportunity to respond to this important review of RTS 153/2013 and accompanying guidelines, in light of the procyclicality witnessed during the peak volatility of the Covid crisis. European CCPs already have standard anti-procyclicality tools in their rulebooks and this did lead to less volatile moves in margin in Europe versus other jurisdictions.
Closet Index Funds
EFAMA has reviewed ESMA’s statement “Supervisory work on potential index tracking”, which sets out research to determine whether any indication of closet indexing could be found at EU level. To contribute to the debate on this matter, EFAMA has prepared a paper, which highlights the limits of identifying closet index funds through a statistical analysis, drawing on recently published research papers.