This is a timely and necessary review to which we hope to contribute in a constructive manner. As already recognised in the consultation paper and in the MiFID Quick Fix proposal, RTS 27 and RTS 28 currently fall short of the objective of providing valuable and comparable datasets for investment managers and the investing public. We appreciate the present effort to revise reporting requirements to produce more meaningful reports.
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.
EFAMA’s response to ESMA’s Review of the MiFID II framework on best execution reports
Industry Approach to CSDR Settlement Discipline Regime
The Joint Associations1 welcome clarification from ESMA that national competent authorities are expected not to prioritise supervisory actions in relation to the application of the CSDR buy-in regime.2
Joint Statement on EU Commission proposal for revised Market in Financial Instrument Regulation (MiFIR)
We see great value in the creation of a consolidated tape to support Europe’s capital markets. However, we qualify that statement with a reminder that the framework for a successful consolidated tape should
i) address the known market failure around market data costs,
Robust governance needed for future consolidated tape providers
ESMA technical standards move one step closer to consolidated tape launch.
ESMA recently closed the consultation for regulatory technical standards that will define the competitive selection process for the consolidated tape, as well as the technical abilities that applicants will be assessed on. In its response for the buy-side, EFAMA stressed that a robust governance framework for the operators of the tapes is critical.
Households continue to keep a disproportionate amount of money in bank deposits in most European countries
New report calls for action to be taken to revive the Capital Markets Union project
Household Participation in Capital Markets
This report analyses the progress made in recent years by European households in allocating more of their financial wealth to capital market instruments (pension plans, life insurance, investment funds, debt securities and listed shares) and less in cash and bank deposits. It also includes policy recommendations on improving retail participation in capital markets, including for the Retail Investment Strategy currently under discussion.
Some key findings include:
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.