EFAMA has today published its European Quarterly Statistical Release for Q2 of 2023.
EFAMA has today published its European Quarterly Statistical Release for Q2 of 2023.
EFAMA, BFPI Ireland, EACB, FIA EPTA, Federation of the Dutch Pension Funds, Finance Denmark, Nordic Securities Association, AIMA, ICI Global, FIA and ISDA, which collectively represent major European end users of derivatives along with providers of clearing services, have published a joint statement on the European Commission’s proposed active account requirement under the European Market Infrastructure Regulation (EMIR 3.0).
EFAMA, BFPI Ireland, EACB, FIA EPTA, Federation of the Dutch Pension Funds,
Finance Denmark, Nordic Securities Association, AIMA, ICI Global, FIA and ISDA support positive
incentives to further enhance the attractiveness of EU clearing and EU Capital Markets, including
many of the measures proposed in EMIR 3.0. (read more)
The European Commission has taken a significant stride with its newly unveiled proposal on Environmental, Social, and Governance (ESG) rating activities, which aims to provide a more comprehensive understanding of ESG ratings methodologies, data sources, and potential biases, ultimately empowering investors to make informed decisions.
Protecting long-term investors from material dilution is a legitimate objective, however, EFAMA doubts that the FSB draft proposals on structural vulnerabilities in the open-ended fund (OEF) sector and the IOSCO ones on anti-dilution liquidity management tools (LMTs) would increase the resilience of the OEF sector. In our view, this framework would add unnecessary complexity to liquidity risk management and, ultimately, result in higher costs for end-investors with little benefit.
EFAMA welcomes the IOSCO Consultation report which we believe is a good starting point for further engagement with our industry on dilution in Open-Ended Funds (OEFs). We believe that dilution may indeed trigger investor protection concerns for certain funds and welcome, in this respect, IOSCO’s commitment to protect end-investors from material dilution. This being said, we however do not support the consultation report’s significant emphasis on financial stability considerations.
EFAMA welcomes the opportunity of this consultation report to share views on how regulators could foster greater consistency in the management of liquidity risks in the Open-Ended Funds (OEFs) sector and on how the FSB should proceed in the future to evaluate any potential build-up of systemic risks in capital markets.
Environmental, social, and governance (ESG) considerations play a crucial role in asset managers' investment decisions for several reasons:
EFAMA appreciates the opportunity to comment on the EMIR 3.0 proposal reforming the clearing framework in the EU. We share the objectives of this review which seek to ensure financial stability in the EU, and the well-functioning of the existing central clearing framework. We understand the objective to reduce excessive exposure to substantially systemic CCPs over time, though we maintain that any regulatory measures should be proportionate to the regulatory rationale, and should not unduly harm market participants.
EFAMA commented on IASB’s ED on IAS 12 (Pillar Two Model Rules). As the model rules drafted by the OECD establish that investment funds and investment entities should be carved out / excluded from Pillar Two, at first glance we expect them would not have a significant impact on our industry (at least on the strict product/funds side). While it is still to be confirmed what will be required from asset management firms and investors investing in funds to comply with the new rules, it is clear the analysis is highly complex.
EFAMA welcomes ESMA's consultation paper on guidelines on funds’ names using ESG or sustainability-related terms. We support the overarching objective to promote transparency and tackle the risk of greenwashing by ensuring that investors are protected against unsubstantiated or exaggerated sustainability claims.
The MiFID/MiFIR review will be key to the future success and competitiveness of the EU's capital markets.
With international competition for investment heating up markedly, European legislators need to ensure that EU regulation is helping, and not hindering, capital market growth and participation.
Various European trade associations representing EU capital markets, including EFAMA, BVI, EFSA and NSA, have published a letter outlining their main priorities for the review. This includes the following core elements:
In an environment with unclear definitions at EU level on key sustainable finance concepts, as well as a lack of complete, comparable and transparent ESG data, all market actors are concerned about the risk of greenwashing.
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