EFAMA is grateful for the opportunity to contribute to the drafting of the Regulation through a consultation and we appreciate the effort of the regulator to adopt an approach to reporting consistent with EMIR and to develop, where more efficient, a different reporting logic.
Policy
EFAMA’s reply to ESMA’s Discussion paper on draft RTS and ITS under the Securities Financing Transaction Regulation
EFAMA response on OECD Public Discussion Draft on the treaty entitlement of Non-CIVs
EFAMA is grateful for the opportunity to comment on the OECD Public Discussion Draft related to concerns received by the OECD on previous discussion drafts related to the Report on Action 6, as to how the new provisions included in the Report on Action 6 could affect the treaty-entitlement of nonCIVs. We agree with the aim of the discussion draft to clarify any concerns in relation to the discussion concerning the treaty entitlement of CIVs / Non-CIVs.
EFAMA Response to EIOPA Consultation on PPPs
EFAMA welcomes EIOPA’s consultation and the opportunity to share our views on EIOPA’s recommendations to develop an EU single market for personal pensions.
EFAMA supports the conclusions of EIOPA’s impact assessment:
• The standardization of key elements of a PEPP - as proposed by EIOPA in its advice - with space to accommodate the specificities of Member States, is the best policy option.
• It would be difficult to achieve full standardization via harmonization because this would require bringing all national regulations on PPPs to one level.