EFAMA welcomes ESMA’s Call for Evidence on asset segregation and custody services as a precious occasion to confirm our previous key messages - as per our response to the previous consultation around Guidelines on asset segregation under the AIFMD of December 2014 – and to clarify our position on new aspects of ESMA’s work.
EU Fund regulation
The EU fund product landscape is deep, diverse and dynamic. Since the birth of the UCITS framework in 1985, European institutions have progressively refined it into a global “gold standard”, one that successfully balances strict regulatory requirements with the flexibility required by manager to meet evolving client demands. The successful evolution of UCITS was followed by the creation of alternative investment funds (AIFs) under the 2011 AIFM Directive, adding a second important pillar to EU fund/manager regulation. Building on this second pillar are further ambitious EU fund products, such as EUSEFs, EUVECAs and ELTIFs. EFAMA has helped guide all of these key regulatory developments, informing policymakers and regulators on their main merits and drawbacks, while also keeping a close eye on their respective review initiatives.
EFAMA strongly supports a fundamental review to the ELTIF regime, in view of broadening its eligible investment universe and adapting it to better meet retail investor needs. We are also closely monitoring the review of the AIFM Directive from a product regulation standpoint, including possible spillover effects on the UCITS Directive requirements. Further work involves keeping pace with relevant ESMA initiatives, such as the work around the Common Supervisory Action on costs and fees for UCITS.
EFAMA welcomes the opportunity to respond to the European Commission’s Green Paper on retail financial services. Widening the opportunities for European citizens to save and invest will facilitate better outcomes both for savers and the wider European economy.
EFAMA fully shares the goals of a Single Market for retail financial services in the EU, i.e.:
1. Promoting an EU-wide market in retail financial services that can facilitate cross-border business and consumer choice.
Our corporate members are both subsidiaries of an EEA parent that is a credit institution as per Article 4(1)(1) of the CRR, or stand-alone investment firms as per Article 4(1)(2) of the CRR. Both types of entities risk becoming subject to the Maximum Ratio Rule as asset management companies licensed under either a UCITS or AIFM management company license, or licensed as investment firms under the MiFID regime to provide discretionary portfolio management services on a client-by-client basis.
The European Fund and Asset Management Association (EFAMA) has today published its latest monthly Investment Fund Industry Fact Sheet, which provides net sales data of UCITS and AIFs for October 2020*.
Bernard Delbecque, Senior Director for Economics and Research commented: "Net sales of UCITS equity funds, although remaining positive, fell to a very low level in October against the backdrop of increases in Covid-19 cases and new lockdown measures."
The main developments in October 2020 can be summarized as follows:
The European Fund and Asset Management Association (EFAMA) has today published its latest quarterly international statistics, tracking and analysing trends in worldwide regulated open-ended fund assets and flows for Q3 2020.
The European Fund and Asset Management Association (EFAMA) has today published its Quarterly Statistical Release describing the trends in the European investment fund industry
The report aims to provide a unique and comprehensive set of facts and figures on the state of the industry at the end of 2018 but also to highlight the fundamental role of asset managers in the financial system and wider economy.
European MMFs in the Covid-19 market turmoil: Evidence, experience and tentative considerations around eventual future reforms
The pandemic-induced market events experienced in March 2020 have marked the first true ‘stress-test’ for European MMFs, following the introduction of the EU Money Market Fund Regulation (MMFR) in 2017. Despite the severity of the liquidity stress in the secondary market for short-term instruments and the significant outflows experienced by European MMFs across all three of the MMFR-identified categories (public debt CNAV, LVNAV and VNAV), funds proved resilient.
Through its ETF Task Force, EFAMA has produced an Investor Education Guide intended to draw out, in a simple form, the defining features for the three main types of ETPs (Exchange-traded products) listed across European markets. The association hopes this guide will primarily assist investors in having a clearer understanding of different ETPs and help investors appreciate the differences between them, especially from a risk and product complexity viewpoint.