EFAMA welcomes the consultation that the European Commission launched on the cross-border distribution of different types of investment funds (AIFs, UCITS, EuVECA/EuSEF, and ELTIF) and the opportunity to respond as to the remaining barriers to marketing funds across the EU single market, as well as the ways to eliminate them. We, also, fully share the goal of the European Commission in seeking further ways to deepen the Single Market for investment funds.

EFAMA welcomes ESMA’s Call for Evidence on asset segregation and custody services as a precious occasion to confirm our previous key messages - as per our response to the previous consultation around Guidelines on asset segregation under the AIFMD of December 2014 – and to clarify our position on new aspects of ESMA’s work.

EFAMA firstly wishes to commend the FSB’s change of focus in the course of 2015, from a proposed assessment methodology intended to identify non-bank, non-insurance globally systemically important financial institutions (NBNI G-SIFIs) to a revised and more objective focus on asset management activities. Although we understand the former framework may be revisited by the FSB once its Recommendations are finalised, we appreciate that certain key characteristics of the asset management industry have been recognised and well reflected in the present consultative document.