Andreas Stepnitzka, EFAMA Deputy Director, Regulatory Policy, comments:
EFAMA monitors issues surrounding fund distribution and disclosures to investors. These include investor protection and disclosure issues arising from the evolving PRIIPs and MiFID frameworks, the shift towards digital distribution tools, and the continued integration of ESG considerations into fund products.
Andreas Stepnitzka, EFAMA Deputy Director, Regulatory Policy, comments:
EFAMA provided high-level comments to the Commission’s consultation on the potential review of the Directive on Distance Marketing of Consumer Financial Services.
We agree with the Commission’s interpretation that the Directive is seen as a “safety net” for financial services not already subject to product-specific legislation. Fund and asset managers are already subject to various, more stringent and detailed sectoral legislations, such as (but not limited to) UCITS, AIFMD and MiFID as well as the (more recent) Cross-Border Fund Distribution Directives.
The European Commission recently adopted amendments to the Packaged Retail and Insurance-based Investment Products (PRIIPs) Regulation and the Undertakings for Collective Investment in Transferable Securities (UCITS) Directive. However, in contrast to earlier plans, the adoption of the revised Regulatory Technical Standards (RTS) amending Commission Delegated Regulation (EU) 2017/653 has been postponed.
EFAMA appreciates the opportunity to respond to the IOSCO Retail Market Conduct Task Force's consultation on retail investment trends.
In our view, the IOSCO report provides a comprehensive picture of the retail market trends and risk magnifiers.
We also take the opportunity to share our views on the following areas:
EFAMA places huge importance on this revision of ESMA’s suitability guidelines, as they spell out in detail how investors can invest in sustainable investment products. If they are well designed, the guidelines have the potential to significantly boost capital flows towards sustainable investments; a goal that the European fund industry strongly supports.
EFAMA appreciates the opportunity to share our views on the European Commission’s consultation on enhancements to the suitability and appropriateness assessments forming part of the wider, upcoming Retail Investment Strategy.
"It gives me great pleasure to provide you with an overview of our activities since our Annual General Meeting in Paris last year. While we were very much looking forward to hosting you all in Brussels this week, the current crisis and associated travel restrictions has forced us to improvise and turn our meeting into a virtual AGM.