EFAMA appreciates the opportunity to comment on the European Commission's Targeted consultation on open finance framework and data sharing in the financial sector.
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 appreciates the opportunity to comment on the European Commission's Targeted consultation on open finance framework and data sharing in the financial sector.
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.
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:
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.
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.