

In the 9th issue of our “3 Questions 2” (3Q2) series, we spoke with Stuart Corrigall, Chair of the EFAMA Fund Regulation Standing Committee and Managing Director at BlackRock, on ELTIF 2.0.
He answers the following questions:
1: What is an ELTIF, and why did the current ELTIF regime need to be revised?
2: What are the major changes the review process introduced?
3: In light of those changes, is ELTIF 2.0 going to be successful?
EFAMA has today published its latest monthly Investment Fund Industry Fact Sheet, which provides net sales data on UCITS and AIFs for November 2022, at European level and by country of fund domiciliation.
The ongoing review of MiFIDII/MiFIR is an important moment for the future success of the Capital Markets Union project. The European Council adopted their position at the end of last year and the European Parliament is currently debating these future rules, with the expectation of a draft report by the end of the month.
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.
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.
EFAMA has today published its latest monthly Investment Fund Industry Fact Sheet, which provides net sales data on UCITS and AIFs for October 2022, at European level and by country of fund domiciliation.
The European Fund and Asset Management Association (EFAMA) welcomes the opportunity to respond to this important review of RTS 153/2013 and accompanying guidelines, in light of the procyclicality witnessed during the peak volatility of the Covid crisis. European CCPs already have standard anti-procyclicality tools in their rulebooks and this did lead to less volatile moves in margin in Europe versus other jurisdictions.
With the release of this proposal, the Commission is replicating the OECD / BEPS Inclusive Framework (OECD) Pillar Two Global Anti-Base Erosion (GloBE) Model Rules that came live in December 2021 and addresses how Member States will implement them in a coherent and consistent way across the EU. The work of the Commission and the alignment with the work of the OECD / BEPS Inclusive Framework are to be welcomed.
EFAMA fully supports the Commission’s initiatives to fight tax avoidance and aggressive tax planning. The work of the technical teams that acknowledged our industry’s special requirements and the proposal of carve-out rules to protect investment structures and end-investors are, to a certain extent, to be welcomed.
EFAMA appreciates the opportunity to share our views on the European Commission’s consultation on enhancements to the suitability and appropriateness assessments forming part of the wider, upcoming Retail Investment Strategy.
EFAMA welcomes the decision of the European Commission to adopt a targeted approach in its review of the Alternative Investment Fund Management Directive (AIFMD), along with key harmonising provisions within the Undertakings for Collective Investment in Transferrable Securities Directive (UCITSD). This focus on targeted improvements recognises the role this framework has played in encouraging the growth in the European Alternative Investment Fund (AIF) market over the past decade and its resilience even throughout recent market stresses.
EFAMA strongly supports the Commission's draft proposal amending the ELTIF Regulation where it addresses some of the major obstacles that have undermined the attractiveness of the ELTIF product since inception. The revised legal framework has the potential to transform ELTIF into a product of choice for a larger (retail) investor audience, all while serving the purposes of the Capital Markets Union (CMU). However, some important adjustments remain to be made for the ELTIF regime to reach its full potential as a competitive long-term investment option.

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