EFAMA welcomes the opportunity to respond to the European Commission’s consultation envisaging the review of the EU macro-prudential policy framework. The consultation paper emphasises the review of the existing prudential framework built around the systemic nature of credit institutions and at the cornerstone of which lies the CRD/CRR, accompanied by the ESRB Regulation and the foundation of a Single Supervisory Mechanism (SSM) for a Banking Union, in turn revolving around the ECB.
EFAMA welcomes the opportunity to provide its comments on the Good Practices to be adopted by IOSCO for the Termination of Investment Funds. We agree that the decision to terminate a fund can have significant impact on investors in terms of the costs associated with such an action, or the ability for investors to redeem their holdings during the termination process. In this regard, even in the context of a fund’s voluntary termination, asset managers must abide by their fiduciary obligation to act in the best interest of their investors.
Better Finance and EFAMA have always been strong supporters of the “PRIIPs1 ” Key Information Document (“KID”), seeing it as a powerful instrument for retail investors to enable sound investment choices by allowing easier comparisons within a wide range of investment products. In order for this to happen, the rules defining the detailed contents of the PRIIPs KID must be correctly calibrated so that investors are given meaningful, comprehensible and comparable information.
Investors, originators issuers and other market participants represented by the above signatories are committed to supporting a safe and sustainable securitisation market that serves the real economy in Europe.