The European Fund and Asset Management Association (EFAMA) calls on the European Commission to reflect EFRAG´s recommendations for mandatory European Sustainability Reporting Standards in the upcoming NFRD review.

As the European trade association representing numerous ETF issuers, EFAMA welcomes the opportunity of this questionnaire to submit a few high-level considerations to the attention of Committee 5 member supervisors. Our inputs are intended to accompany the more detailed submissions of the several European ETF issuers our association represents, in view of informing the Committee’s future work around a possible review of IOSCO’s 2013 Principles for the Regulation of Exchange Traded Funds.

EFAMA supports the initiatives launched by IOSCO and other regulators (e.g. ESMA, FCA, SEC) to analyse and address the significant issues concerning market data in the secondary equity market.

EFAMA believes that ESMA’s draft ‘marketing communication’ Guidelines still require important clarifications to ensure full alignment between them and MiFID II’s Commission Delegated Regulation Article 44. This alignment is essential to ensure coherent rules for fund management companies and distributors. Unfortunately, parts of the proposed Guidelines are overly prescriptive and may unintentionally make some marketing materials vaguer or even inconsistent with local MiFID requirements for distributors.