Distribution & Client Disclosures

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.

Related policy positions

Policy position

EFAMA's reply to ESMA's CP on MiFIR Review report on the obligations to report transactions & reference data

Capital Markets

Distribution ＆ Client Disclosures

EU Fund regulation

UCITS

23 November 2020

EFAMA's reply to ESMA's CP on MiFIR Review report on the obligations to report transactions & reference data

We disagree with an extension of its scope to UCITS’ and AIFs’ management companies to the scope of the reporting requirements imposed by MiFIR, Art. 26. This extension would be in breach of the principle of proportionality, as:

Policy position

Associations Letter: Integration of sustainability factors and risks into MiFID II IDD and Solvency II

Distribution ＆ Client Disclosures

Management Companies

Sustainable Finance

27 July 2020

Associations Letter: Integration of sustainability factors and risks into MiFID II IDD and Solvency II

Policy position

Capital Markets

MIFID

Distribution ＆ Client Disclosures

Sustainable Finance

08 July 2020

EFAMA responds to EC draft DA on integration of ESG into MiFID II

EFAMA Statement on the ECON Committee’s draft report amending the UCITS directive for PRIIPs

Andreas Stepnitzka, EFAMA Deputy Director, Regulatory Policy, comments:

Policy Position

Distribution ＆ Client Disclosures

Management Companies

29 September 2021

Distance marketing of consumer financial services – Review of EU rules

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.

Press Release

Distribution ＆ Client Disclosures

PRIIPs

09 September 2021

Industry calls for reasonable implementation timeline for PRIIPs changes

EFAMA and several other financial industry associations, raised concerns in response to a consultation conducted by the European Commission on planned changes to the Packaged Retail and Insurance-based Investment Products (PRIIPs) framework.

The unexpected delay to the adoption of the revised PRIIPs RTS cuts the implementation period for the industry by more than two months. This leaves PRIIPs manufacturers and distributors with a too short period instead of the original timeframe of 12 months to implement the new rules.