EFAMA welcomes the opportunity to respond to the EC’s targeted consultation on the functioning of the ESG rating market in the EU and on the consideration of ESG factors in credit ratings. Please note that our response covers, at the same time, ESG ratings and ESG data providers, as the demand for ESG “raw” data has been increasing at a steady pace. The use of ESG data has also rapidly shifted from a narrow set of investment products to being prolific across all investment products.
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.
EFAMA response to EC CfE ESG ratings and sustainability risks in credit ratings
IOSCO Retail Market Conduct Task Force Report
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 response to ESMA’S consultation paper “guidelines on certain aspects of the Mifid II Suitability Requirements”
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.
Investment Funds Distributor Due Diligence Questionnaire
Funds face unique challenges in performing intermediary oversight, and especially so because of MiFID II requirements, changing regulatory landscapes, and the absence of an industry agreed-upon standard between funds and their distribution channels. To help address these challenges, a dedicated working group developed a uniform due diligence questionnaire (DDQ) that will serve as the standard for investment funds (UCITS and AIFs) in performing onboarding and ongoing oversight of distribution channels.
EFAMA calls for changes to investor protection rules in MIFID II / MIFIR Review
EFAMA has submitted its response to the European Commission's consultations on the review of the MIFID II / MIFIR regulatory framework, where it has outlined its recommendations on investor protection and capital markets and infrastructure.
EFAMA's Director General Tanguy van de Werve commented:
EFAMA welcomes final agreement on legislation facilitating cross-border distribution of funds
We welcome yesterday's vote by the European Parliament plenary, formally adopting the trilogue agreement on the Commission's initiative to remove cross-border barriers to the distribution of investment funds.
This marks a decisive recognition of the need to postpone the application of the PRIIPs disclosure regime for UCITS by two years, in light of the regime's documented shortcomings. It also allows the European Commission more time to conduct a thorough review of the same within one year.
Asset Management Report 2021
This is our 13th edition of the Asset Management in Europe report, which provides an in-depth analysis of recent trends in the European asset management industry, focussing on where investment funds and discretionary mandates are managed in Europe.
EFAMA Annual Review 2020-2021
It gives me great pleasure to provide you with an overview of our activities since our Ordinary General Meeting of last year.
Infographic | The challenges of replacing UCITS KIIDs with PRIIP KIDs
In support of our call for additional time to implement the PRIIPs rules, we have produced an infographic that summarises the challenges our members face replacing UCITS KIIDS with PRIIP KIDs. The infographic shows the many entities involved in the process and the steps required to prepare a PRIIP KID. Feel free to make use of this infographic.