In light of the current COVID-19 circumstances and the already existing ambitious time table for the implementation, EFAMA calls for the EBA to carefully consider these circumstances and request the EC to postpone the date for the application of the IFD/IFR framework (26 June 2021) and the time table of the level 2 measures (such as the deadline of 26 December 2020 for providing drafted RTS and ITS).

EFAMA considers the Sustainable Finance Disclosure Regulation (SFDR) and its accompanying technical standards essential pieces in a strong and ambitious framework for sustainable investing. Its feedback aims at improving the effectiveness and feasibility of the ESAs’ proposal, as well as strengthening this regulation’s synergies with existing and upcoming rules.

A holistic approach is recommended when establishing whether the use of leverage of AIFs poses leverage-related systemic risk and materially contributes to financial instability. Any regulatory policies on leverage need to be evidence-based and developed with empirical evidence showing the extent to which the use of leverage in AIFs contributes to the build-up of systemic risk. The Covid-19 pandemic is testament that no major dysfunction was reported in terms of use of leverage by AIFs.

As highlighted in President’s von der Leyen guidelines for the new Commission, the complexity and sophistication of the Union’s financial system has opened the door to new risks of money laundering and terrorist financing. The European Union needs to step up its regulatory framework and preventive architecture to ensure that no loopholes or weak links in the internal market allow criminals to use the EU to launder the proceeds of their illicit activities.