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.
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:
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.
In July the European Commission released their long-awaited Retail Investment Strategy, including multiple proposals aimed at boosting retail participation in capital markets. EFAMA has provided comments on this in their ‘Have your say’ forum, where we briefly highlight some of our main concerns.
EFAMA, together with EBF, Insurance Europe, EACB, EAPB, ESBG and EUSIPA, issued a public letter addressed to Vice-President Dombrovskis, Commissioners McGuinness and Director-General Berrigan, remarking the importance of advice for European retail investors and the need to maintain the coexistence of fee-based and commission-based advice.
ESMA’s Consultation paper on the review of the guidelines on MiFID II product governance requirements
EFAMA wholeheartedly supports ESMA’s objective of ensuring a consistent and harmonised application of the MiFID II product governance requirements. In our response to their consultation on the topic, we raised the following points:
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.