

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.
EFAMA is supportive of the general objectives of the PRIIP KID Regulation. We are however concerned about the very limited time that product manufacturers will have between the final technical rules (RTS) and essential guidelines being published and the deadline to produce Key Information Documents (KIDs) from 31 December 2016 onwards. Having provided extensive feedback throughout the ongoing Level-2 work, we seriously doubt there will be enough time for market participants to implement the final rules by the end of this year, as originally foreseen by the co-legislators.
EFAMA welcomes the opportunity to provide the views of the asset management industry to this challenging exercise of assessing the impacts of recent regulatory reforms in the area of financial services.
There are a number of general remarks that we would like to make by way of introduction.
Need for consistency and coordination
After having looked extensively at the Level-2 work done by the ESAs, EFAMA1 comes to the unfortunate conclusion that, due to the very technical nature of the underlying methodologies and calculations, there will not be enough time for market participants to fully implement the PRIIP KID by 31 December 2016.
Our corporate members are both subsidiaries of an EEA parent that is a credit institution as per Article 4(1)(1) of the CRR, or stand-alone investment firms as per Article 4(1)(2) of the CRR. Both types of entities risk becoming subject to the Maximum Ratio Rule as asset management companies licensed under either a UCITS or AIFM management company license, or licensed as investment firms under the MiFID regime to provide discretionary portfolio management services on a client-by-client basis.
EFAMA welcomes the opportunity to provide comments on ESMA’s Consultation Paper on draft guidelines for the assessment of knowledge and competence.

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