EFAMA firstly wishes to commend the FSB’s change of focus in the course of 2015, from a proposed assessment methodology intended to identify non-bank, non-insurance globally systemically important financial institutions (NBNI G-SIFIs) to a revised and more objective focus on asset management activities. Although we understand the former framework may be revisited by the FSB once its Recommendations are finalised, we appreciate that certain key characteristics of the asset management industry have been recognised and well reflected in the present consultative document.
Management Companies
EFAMA has been looking at legislative proposals with a direct impact on asset management companies and services, and closely follows any regulatory developments of critical importance to the sector. In addition to issues related to risk management and financial stability, high up on the agenda of EFAMA members is the framework for a prudential regime for Investment Firms (IFD/R), and related implementing measures directly descending from such framework.
EFAMA is focused on minimising the impact of the rules on asset management companies, in particular those holding a limited MiFID license. Key to the sector is the need for proportionality, especially firms that are not authorised to hold client money/securities, or to deal on their own account.
EFAMA reply to FSB consultation on proposed policy recommendations to address structural vulnerabilities from asset management activities
EFAMA’s reply to ESMA’s Discussion paper on draft RTS and ITS under the Securities Financing Transaction Regulation
EFAMA is grateful for the opportunity to contribute to the drafting of the Regulation through a consultation and we appreciate the effort of the regulator to adopt an approach to reporting consistent with EMIR and to develop, where more efficient, a different reporting logic.
EFAMA response to Green Paper on Retail Financial Services
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.
EBA & ESMA discussion paper on the Commission’s call for advice on the prudential framework for investment firms
FSB consultation on liquidity preparedness for margin calls in non-bank financial intermediation
EFAMA agrees with the FSB that market participants should integrate the management of margin and collateral calls into their risk management, governance, and operational processes.
EFAMA’s position on the EC's review of the AIFM and UCITS directives
We welcome the targeted approach of the Commission in its review, recognising the overall success of the frameworks over the past decade.