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 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.
The European Fund and Asset Management Association (EFAMA) has today published its International Quarterly Statistical Release regarding the developments in the worldwide investment fund industry during the fourth quarter of 2021.
The European ESG Template (EET) is meant to facilitate the necessary exchange of data between product manufacturer and distributor for the purpose of fulfilling ESG-related regulatory requirements contained in the SFDR, relevant provisions of the Taxonomy Regulation, and the relevant delegated acts complementing MiFID II and IDD. The EET V1 is based on the regulatory situation on the day of publication and will be reviewed regularly depending on the evolving regulation, and at least confirmed annually. With regard to the MiFID target market, the EET interacts with the EMT V4.
EFAMA released today issue number eight of its Market Insights series titled 'The Costs of UCITS and US Mutual Funds - We can only compare like with like'. This
We welcome the targeted approach of the Commission in its review, recognising the overall success of the frameworks over the past decade.
On behalf of:
CDP, Economy for the Common Good, EFAMA, Eurosif, Frank Bold, Finance Watch, Global Witness, Investor Alliance for Human Rights, Publish What You Pay, ShareAction, Transport and Environment, WWF
Dear Members of the European Parliament,
European Fund trends in Q4 2021 – Further slowdown in the net sales of long-term UCITS
The European Fund and Asset Management Association (EFAMA) has today published its latest monthly Investment Fund Industry Fact Sheet, which provides net sales data on UCITS and AIFs for December 2021, at European level and by country of fund domiciliation. A first overview of the net sales data of UCITS and AIFs over the full year 2021 is also included.
FIA, ISDA, AFME, ICI, AIMA, EBF and EFAMA (together the Associations) welcome the
European Commission's (the Commission) timely and temporary equivalence decision from
21 September 2020 with respect to UK central counterparties (CCPs) and subsequent
recognition decisions by ESMA of CCPs and the recent temporary equivalence decision for
UK Central Securities Depositories (CSDs) under CSDR. Together, these steps have provided
much needed certainty for continued and uninterrupted access to these CCPs and CSDs by
EFAMA has some concerns with ESMA’s clarifications. In the consultation paper (CP), ESMA seems to have a very broad interpretation of the ‘multilateral systems’ definition under MiFID II and states that ‘systems where trading interests can interact but where the execution of transactions is formally undertaken outside the system still qualify as a multilateral system and should be required to seek authorisation’ (paragraph 36).
We disagree with an extension of its scope to UCITS’ and AIFs’ management companies to the scope of the reporting requirements imposed by MiFIR, Art. 26. This extension would be in breach of the principle of proportionality, as:
Article 51(5) of the BMR provides that, unless the Commission has adopted an equivalence decision in relation to a particular third country, a third country administrator has been recognised or a third country benchmark has been endorsed, EU supervised entities may only use a third country benchmark in financial instruments, financial contracts and measurements of the performance of an investment fund that already reference the relevant benchmark prior to 31 December 2021.
EFAMA is grateful for the opportunity to comment on some messages included in the aforementioned roadmap. We believe that these comments should be made clear for all persons interested, especially to those who would like to participate in the upcoming public consultation.
Asset managers represent an important group of benchmark users, either in the case of index funds and exchange traded funds (ETFs) - where benchmarks are used as a target for index tracking funds - or in the case of the evaluation of an active manager’s performance - where the fund performance is measured against a selected index or a set of indices.

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