Andreas Stepnitzka, EFAMA Deputy Director, Regulatory Policy, comments:
Andreas Stepnitzka, EFAMA Deputy Director, Regulatory Policy, comments:
EFAMA has today published its latest monthly Investment Fund Industry Fact Sheet, which provides net sales data on UCITS, and AIFs sold in August 2021, at European level and by country of fund domiciliation.
The Commission aims to present a legislative proposal to address the tax-induced debt-equity bias, also to support the action plan for the Capital Markets Union and to encourage companies to finance their investment through equity contributions rather than through debt financing.
“Oliver Wyman’s study ‘Caught on Tape’ provides a perplexing take on Consolidated Tape for Europe. Sure enough, it starts with accurate observations: the high number of trading venues in Europe, the resultant fragmented liquidity, unseen liquidity due to the lack of a consolidated tape, and the fact that leading markets like the US and Canada today benefit from a real time consolidated tape.
The current lack of quality pre- and post-trade data and the fragmentation of data sources remain an obstacle to the completion of the Capital Markets Union. The benefits of a real-time Consolidated Tape are wide-ranging: from market surveillance for supervisors, to best execution and an improved view on trading opportunities for retail investors, to portfolio management and pre- and post-trade analysis for fund managers to name a few.
EFAMA has been at the forefront of efforts to urge authorities to raise financial literacy levels in the general population through widespread and improved financial and investor education initiatives. We are also a long-time supporter of IOSCO's World Investor Week and organise a yearly event on investor education.
The old-age dependency ratio in the EU continues to increase; Eurostat’s recent figures project that by 2050, there will be fewer than 2 working-age adults for each person aged 65 or older, versus just under 3 today.
Investor education initiatives are essential to improve financial literacy and empower citizens to make sound decisions when managing their savings. If citizens do not have the basic knowledge to understand financial concepts such as risk diversification, compound interest and real rate of return, they won’t know where to start or what to ask should they wish to invest their savings. A lack of sufficient financial literacy in most European countries helps explain why the vast majority of households don’t directly invest any of their savings in the capital markets.
In a letter to policymakers, 18 European buy-side firms state that only an Equities/ETFs tape that delivers data in real-time and that includes pre-trade data in the form of 5 layers of best bid and offer, will meet with the necessary market demand to make the Equities/ETFs Consolidated Tape commercially viable. A reasonably priced tape is also a precondition for success, they argue.
EFAMA comments the European Commission's ViDA Proposal and welcomes the consistency of the proposal and the fact that VAT-exempt services will not be covered by the new DDR. With this solution, the proposal should allow tax authorities to focus on the real risk of tax fraud cases and should not create new burdensome procedures/compliance obligations that would represent new costs that in the end would be imposed on clients/consumers (e.g. end investors) for no reason.
EFAMA appreciates the opportunity to comment on the EMIR 3.0 proposal reforming the clearing framework in the EU. We share the objectives of this review which seek to ensure financial stability in the EU, and the well-functioning of the existing central clearing framework. We understand the objective to reduce excessive exposure to substantially systemic CCPs over time, though we maintain that any regulatory measures should be proportionate to the regulatory rationale, and should not unduly harm market participants.
EFAMA commented on IASB’s ED on IAS 12 (Pillar Two Model Rules). As the model rules drafted by the OECD establish that investment funds and investment entities should be carved out / excluded from Pillar Two, at first glance we expect them would not have a significant impact on our industry (at least on the strict product/funds side). While it is still to be confirmed what will be required from asset management firms and investors investing in funds to comply with the new rules, it is clear the analysis is highly complex.
EFAMA welcomes ESMA's consultation paper on guidelines on funds’ names using ESG or sustainability-related terms. We support the overarching objective to promote transparency and tackle the risk of greenwashing by ensuring that investors are protected against unsubstantiated or exaggerated sustainability claims.

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