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.

Related policy positions

Policy Position

Distribution ＆ Client Disclosures

27 April 2022

EFAMA response to ESMA’S consultation paper “guidelines on certain aspects of the Mifid II Suitability Requirements”

EFAMA places huge importance on this revision of ESMA’s suitability guidelines, as they spell out in detail how investors can invest in sustainable investment products. If they are well designed, the guidelines have the potential to significantly boost capital flows towards sustainable investments; a goal that the European fund industry strongly supports.

Policy Position

Distribution ＆ Client Disclosures

22 March 2022

EFAMA's response to the EU Commission's targeted consultation on options to enhance the suitability and appropriateness assessments

EFAMA appreciates the opportunity to share our views on the European Commission’s consultation on enhancements to the suitability and appropriateness assessments forming part of the wider, upcoming Retail Investment Strategy.

Policy position

Distribution ＆ Client Disclosures

PRIIPs

15 December 2021

EFAMA response to ESA’s Joint Committee call for evidence on PRIIPs

EFAMA continues to support the overarching aim of the PRIIP KID as a single pre-disclosure document for all types of investment products.

EFAMA believes that the ESAs Joint Call for Evidence on PRIIPs and any subsequent proposals for revision of the PRIIPs Regulation should come after assessing in practice the revised PRIIPs RTS to be implemented from 31 December 2022, both to retail AIFs and UCITS.

Industry calls for reasonable implementation timeline for PRIIPs changes

EFAMA and several other financial industry associations, raised concerns in response to a consultation conducted by the European Commission on planned changes to the Packaged Retail and Insurance-based Investment Products (PRIIPs) framework.

The unexpected delay to the adoption of the revised PRIIPs RTS cuts the implementation period for the industry by more than two months. This leaves PRIIPs manufacturers and distributors with a too short period instead of the original timeframe of 12 months to implement the new rules.

Policy Position

Distribution ＆ Client Disclosures

PRIIPs

EU Fund regulation

Management Companies

04 August 2021

EU retail investments: comprehensive strategy to increase retail investor participation required

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.

Publication

Capital Markets Union

Competitiveness

Distribution ＆ Client Disclosures

EU Fund regulation

International agenda

Investor Education

Management Companies

Pensions

Stewardship

Sustainable Finance

10 June 2021

EFAMA Annual Review 2020-2021

It gives me great pleasure to provide you with an overview of our activities since our Ordinary General Meeting of last year.

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Related publications

Publication

MIFID

Distribution ＆ Client Disclosures

PRIIPs

Management Companies

AIFMD

03 June 2020

Investment Funds Distributor Due Diligence Questionnaire

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.

Publication