In our latest Monthly Statistical Release, we show the main developments for the European investment fund market in December 2024 and include a first overview and analysis of the full year 2024.
In our latest Monthly Statistical Release, we show the main developments for the European investment fund market in December 2024 and include a first overview and analysis of the full year 2024.
Today, the European Fund and Asset Management Association (EFAMA) published the 20th issue of its Market Insights series, titled “Beyond fund consolidation: a more promising strategy for bigger funds and faster cost declines in Europe”. This publication compares the size and number of equity UCITS with that of US equity mutual funds and challenges the commonly held belief that fund consolidation will significantly lower the cost of funds in Europe.
In its recently published market report on the costs and performance of EU retail investment products, ESMA asserts that there are “substantial differences in the fund cost level between the EU and the US”. In its accompanying press release, ESMA emphasizes that “the market inefficiencies revealed by this higher cost level show the need to focus on the competitiveness of EU markets, within a future Savings and Investments Union.”
Since recent market disruptions such as the COVID-19 pandemic, the Financial Stability Board (FSB) and the International Organization of Securities Supervisors (IOSCO) have investigated how to make investment funds more resilient to liquidity shocks. The FSB published their recommendations in December 2023 and IOSCO is now looking into how to adjust their own 2018 recommendations along these lines.
In its response to IOSCO’s consultation on the revised recommendations for liquidity risk management for collective investment schemes, EFAMA welcomes the fact that IOSCO recognises aspects essential for proper risk management (e.g., asset managers’ primary responsibility and the absence of one-size-fits-all approaches).
Representatives of the EU and UK-based financial services industries met today (11 February 2025) in Brussels to discuss their respective priorities and shared challenges on the eve of the latest EU-UK Financial Regulatory Forum meeting and agreed on the following statement.
In its current form, the Retail Investment Strategy (RIS) will not achieve its goal of making investing more accessible to European citizens and could deter, rather than encourage, retail participation. In order to stand a chance of delivering on its objectives, the RIS needs urgent simplification. EFAMA have produced a short leaflet with our recommendations on how to simplify and reduce complexity in the current proposal.
Our key suggestions include:
Supervisory convergence is a core element of the Single Market and integral to removing barriers to cross-border provision of financial services. It is not enough to have a common rule book, but also the reading of those rules by supervisors and supervisory practices should converge to ensure the Single Market is not hampered by diverging interpretations and gold-plating of EU rules.
• EFAMA reiterates the European asset management industry’s strong support for the CMU project in all its dimensions. We welcome the range of initiatives, from the overarching aim of rebuilding confidence in financial markets by putting investors’ interests at the heart of the project, to the promotion of market-based financing of the economy, the development of a PEPP or the development of a comprehensive strategy on sustainable finance.
EFAMA is grateful for the opportunity to comment on the new OECD Public Discussion Draft on BEPS Action 6 and the treaty entitlement of non-CIV funds Discussion Draft on non-CIV examples. In addition EFAMA would like to make positive use of this opportunity and comment as well on the general situation of CIVs as well as of Non-CIVs against the background of the BEPS Action 6 implementation.
EFAMA welcomes the opportunity to respond to the EBA on its proposal for a new prudential regime for investment firms. As the EBA is aware, the activity of portfolio management on behalf of thirdparty clients broadly falls under three separate EU legal regimes:
i. Individual discretionary portfolio management performed by investment firms on a client-byclient basis, authorised under and complying with the Markets in Financial Instruments Directive, as per Annex I Section A, point 4 (as recently amended by MiFID II);
EFAMA welcomes ESMA’s Consultation Paper on product governance requirements and specifically on the target market assessment and supports that the details of these requirements are laid out in the form of guidelines rather than Q&A. We agree with ESMA that drafting target market guidelines is an important aspect “for ensuring the common, uniform and consistent application” of the MIFID II product governance requirements, in particular since these rules have the potential to significantly alter the European distribution landscape.

Discover the 6 reasons why your organisation should become a member of EFAMA.
Our members enjoy significant benefits including the opportunity to shape the industry positions, get first-hand access to regulatory and political intelligence, engage with industry peers and policymakers, and take part in EFAMA events.
Our three membership categories cater to the wide range of organisations that make up and support the investment management industry in Europe.