European asset managers welcome the joint statement from the European Commission, ESMA and the ECB putting a firm foot forward, and ‘accelerating the technical work’ needed to prepare the EU’s T1 transition
European asset managers welcome the joint statement from the European Commission, ESMA and the ECB putting a firm foot forward, and ‘accelerating the technical work’ needed to prepare the EU’s T1 transition
The European T+1 Industry Task Force, comprising 21 trade associations involved in European capital markets, was established in 2023 to bring together a diverse group of industry stakeholders who would be impacted by a move to a default T+1 settlement cycle for securities traded and settled in the EU.
EFAMA has released a joint statement together with AFME (Association for Financial Markets in Europe), EFSA and the Nordic Securities Association on significant issues with the supervision of market data costs.
Clarification is urgently needed to enable rather than restrict EU sustainable investment
The EU has been at the forefront of green bond issuances, demonstrating strong growth and commitment to sustainable finance. However, ESMA’s new Fund Naming Guidelines create inconsistencies with other sustainable finance regulations, like the EU Green Bond Standard, which could hamper the growth of the corporate green bond sector.
The Associations fully support ESMA’s aim of providing for an adequate level of transparency. This will be beneficial to investors, liquidity providers, other intermediaries, as well as issuers, across the entire range of different and diverse bond classes.
EFAMA publishes its latest Monthly Statistical Release for July 2024.
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 is the representative association for the European investment management industry. EFAMA represents through its 28 member associations and 62 corporate members EUR 21 trillion in assets under management of which EUR 12.6 trillion managed by 56,000 investment funds at end 2015. Just over 30,000 of these funds were UCITS (Undertakings for Collective Investments in Transferable Securities) funds, with the remaining 25,900 funds composed of AIFs (Alternative Investment Funds). Our industry provides significant and stable flows of finance to the European economy.
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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