EFAMA has today published its European Quarterly Statistical Release for Q2 of 2023.
EFAMA has today published its European Quarterly Statistical Release for Q2 of 2023.
EFAMA, BFPI Ireland, EACB, FIA EPTA, Federation of the Dutch Pension Funds, Finance Denmark, Nordic Securities Association, AIMA, ICI Global, FIA and ISDA, which collectively represent major European end users of derivatives along with providers of clearing services, have published a joint statement on the European Commission’s proposed active account requirement under the European Market Infrastructure Regulation (EMIR 3.0).
EFAMA, BFPI Ireland, EACB, FIA EPTA, Federation of the Dutch Pension Funds,
Finance Denmark, Nordic Securities Association, AIMA, ICI Global, FIA and ISDA support positive
incentives to further enhance the attractiveness of EU clearing and EU Capital Markets, including
many of the measures proposed in EMIR 3.0. (read more)
The European Commission has taken a significant stride with its newly unveiled proposal on Environmental, Social, and Governance (ESG) rating activities, which aims to provide a more comprehensive understanding of ESG ratings methodologies, data sources, and potential biases, ultimately empowering investors to make informed decisions.
Protecting long-term investors from material dilution is a legitimate objective, however, EFAMA doubts that the FSB draft proposals on structural vulnerabilities in the open-ended fund (OEF) sector and the IOSCO ones on anti-dilution liquidity management tools (LMTs) would increase the resilience of the OEF sector. In our view, this framework would add unnecessary complexity to liquidity risk management and, ultimately, result in higher costs for end-investors with little benefit.
EFAMA welcomes the IOSCO Consultation report which we believe is a good starting point for further engagement with our industry on dilution in Open-Ended Funds (OEFs). We believe that dilution may indeed trigger investor protection concerns for certain funds and welcome, in this respect, IOSCO’s commitment to protect end-investors from material dilution. This being said, we however do not support the consultation report’s significant emphasis on financial stability considerations.
EFAMA welcomes the opportunity of this consultation report to share views on how regulators could foster greater consistency in the management of liquidity risks in the Open-Ended Funds (OEFs) sector and on how the FSB should proceed in the future to evaluate any potential build-up of systemic risks in capital markets.
Environmental, social, and governance (ESG) considerations play a crucial role in asset managers' investment decisions for several reasons:
The fund and asset management industry is a highly regulated industry operating under significant and specific legal, regulatory, transfer pricing and tax frameworks.
Pillar 1: Investment funds are structured as tax neutral investment pooling vehicles as a matter of
public policy.
Pillar 2: The role that investment funds play in providing investors with a diversified portfolio and global market access is essential.
In its support of the development and implementation of the Taxonomy Regulation, EFAMA believes that reporting on the level of alignment with the Taxonomy by non-financial and financial undertakings is essential to strengthening market integrity around sustainability issues.
FIA, ISDA, AFME, ICI, AIMA, EBF and EFAMA (together the Associations) welcome the
European Commission's (the Commission) timely and temporary equivalence decision from
21 September 2020 with respect to UK central counterparties (CCPs) and subsequent
recognition decisions by ESMA of CCPs and the recent temporary equivalence decision for
UK Central Securities Depositories (CSDs) under CSDR. Together, these steps have provided
much needed certainty for continued and uninterrupted access to these CCPs and CSDs by
EFAMA has some concerns with ESMA’s clarifications. In the consultation paper (CP), ESMA seems to have a very broad interpretation of the ‘multilateral systems’ definition under MiFID II and states that ‘systems where trading interests can interact but where the execution of transactions is formally undertaken outside the system still qualify as a multilateral system and should be required to seek authorisation’ (paragraph 36).
We disagree with an extension of its scope to UCITS’ and AIFs’ management companies to the scope of the reporting requirements imposed by MiFIR, Art. 26. This extension would be in breach of the principle of proportionality, as:
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