EFAMA welcomes the opportunity to respond to the EC’s targeted consultation on the functioning of the ESG rating market in the EU and on the consideration of ESG factors in credit ratings. Please note that our response covers, at the same time, ESG ratings and ESG data providers, as the demand for ESG “raw” data has been increasing at a steady pace. The use of ESG data has also rapidly shifted from a narrow set of investment products to being prolific across all investment products.
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.
EC CfE ON RETAIL INVESTMENT – NEW PACKAGE OF MEASURES TO INCREASE CONSUMER PARTICIPATION IN CAPITAL MARKETS
EFAMA wholeheartedly supports a retail investment strategy that gives EU citizens the necessary tools and the confidence to put their savings to work by investing in capital markets.
EFAMA appreciates the opportunity to respond to the IOSCO Retail Market Conduct Task Force's consultation on retail investment trends.
In our view, the IOSCO report provides a comprehensive picture of the retail market trends and risk magnifiers.
We also take the opportunity to share our views on the following areas:
It gives me great pleasure to provide you with an overview of our activities since our Ordinary General Meeting of last year.
In support of our call for additional time to implement the PRIIPs rules, we have produced an infographic that summarises the challenges our members face replacing UCITS KIIDS with PRIIP KIDs. The infographic shows the many entities involved in the process and the steps required to prepare a PRIIP KID. Feel free to make use of this infographic.
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.
Funds face unique challenges in performing intermediary oversight, and especially so because of MiFID II requirements, changing regulatory landscapes, and the absence of an industry agreed-upon standard between funds and their distribution channels. To help address these challenges, a dedicated working group developed a uniform due diligence questionnaire (DDQ) that will serve as the standard for investment funds (UCITS and AIFs) in performing onboarding and ongoing oversight of distribution channels.