This article has been published on ESG Investor
This article has been published on ESG Investor
EFAMA has published its latest Monthly Statistical Release for June 2024.
Thomas Tilley, Senior Economist at EFAMA, commented: “The ECB rate cut of early June resulted in strong net inflows into bond UCITS throughout the month.”
The main developments in June can be summarised as follows:
62,000+ new fund share classes have been added, including new categories
ESMA technical standards move one step closer to consolidated tape launch.
ESMA recently closed the consultation for regulatory technical standards that will define the competitive selection process for the consolidated tape, as well as the technical abilities that applicants will be assessed on. In its response for the buy-side, EFAMA stressed that a robust governance framework for the operators of the tapes is critical.
EFAMA supports achieving greater transparency through reform of the bond deferral regime. We would like to offer some feedback that suggests a different calibration on both liquidity thresholds, and the determination of trade size buckets.
We appreciate the analysis carried out by ESMA, which offers a solid basis for the review of the bond deferral regime. Nevertheless, we would like to provide some feedback on the proposed approach, which we believe can be further finetuned:
ESMA’s Call for Evidence on the UCITS Eligible Assets Directive is a welcome opportunity to take stock of the existing UCITS framework.
EFAMA welcomes the launch of this public consultation to evaluate and assess the effectiveness, efficiency and continued relevance of the DAC and its amendments (DAC2 to DAC6), as well as its coherence with other policy initiatives, priorities and the EU added value.
• 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.
EFAMA is closely monitoring the recent regulatory developments in the field of anti-money laundering and counter-terrorist financing, in particular the due diligence duties of the asset management sector. EFAMA is embracing the objective of enhancing transparency and accessibility to the beneficial ownership information and also fully acknowledges the importance of obtaining accurate identification and verification data of natural and legal persons for fighting money laundering and terrorist financing.
EFAMA supports every efforts made to enhance financial markets regulation which reinforces the stability and the transparency of the financial system.
In that perspective, EFAMA welcomes the opportunity to comment on the ESMA Consultation Paper on RTS specifying the scope of the consolidated tape for non-equity financial instruments. We consider that a consolidate tape (“CT”) is a key positive factor for price formation and transparency.
Prior to replying to the consultation, we wish to make the following general remarks

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