EFAMA agrees in principle with many of ESMA’s suggested approaches in their consultation on guidelines on certain aspects of the MIFID II appropriateness and execution-only requirements.
Distribution & Client Disclosures
EFAMA monitors issues surrounding fund distribution and disclosures to investors. These include investor protection and disclosure issues arising from the evolving PRIIPs and MiFID frameworks, the shift towards digital distribution tools, and the continued integration of ESG considerations into fund products.
EFAMA welcomes the ESAs’ official approval of the revised PRIIPs RTS and is now awaiting the Commission’s endorsement to have the RTS approved by the European co-legislators.
Originally, the Commission had intended to endorse the revised RTS by Q1 2020. With less than nine months remaining until the 31 December 2021 implementation deadline, there is now simply not enough time for fund managers and other product manufacturers to properly implement the envisaged wide-ranging changes. We explain why in more detail below.
A flawed review process not tackling the heart of the issue
EFAMA has always made it clear that a revision of the PRIIPs Regulatory Technical Standard (RTS) falls short of conducting a proper Level 1 review. A review that is explicitly required by the Level 1 Regulation and is overdue for more than one year.
The Financial Data Exchange Templates (FinDatEx) platform today published an interim version of the European MiFID Template (EMT V3.1) which is available on the FinDatEx website. The purpose of this interim version is to answer the demand of product distributors and manufacturers to cope with the basic implementation of MiFID II ESG/SFDR principles, and in view of the misaligned application dates of SFDR Level 1, SFDR RTS and MiFID II delegated acts.
Financial Data Exchange Templates (FinDatEx) platform published on 01 December 2020 the European Feedback Template (EFT V1). This template standardises the information to be sent back from the distributor to the manufacturer under the MiFID 2 target market requirements. This is the first European wide feedback template. The EFT and all other FinDatEx templates are not compulsory, provided to the industry free of charge and are free of any intellectual property rights.
The European Fund and Asset Management Association (EFAMA) has published today the 12th edition of its Asset Management Report*. The report aims to provide a unique and comprehensive set of facts and figures on the state of the industry at the end of 2018 but also to highlight the fundamental role of asset managers in the financial system and wider economy.