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.
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 response to ESMA’S consultation paper “guidelines on certain aspects of the Mifid II Suitability Requirements”
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.
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.
Infographic | The challenges of replacing UCITS KIIDs with PRIIP KIDs
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.
FinDatEx launches interim version of European MiFID Template
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 publishes European Feedback Template
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.
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.