EFAMA leaflet sets out clear recommendations for improvement
The European Fund and Asset Management Association (EFAMA) has launched its AI-system Assessment Tool, which is designed to support firms of all sizes navigate the regulatory complexities of AI. Developed together with EFAMA member experts from across the industry, the Tool will help firms document and assess AI use cases in line with the EU AI Act and other interdependent regulations, including GDPR, MiFIR and DORA, using a free-of-charge standardised tool.
EFAMA has launched its AI-system Assessment Tool, which is designed to support firms of all sizes navigate the regulatory complexities of AI. Developed together with EFAMA member experts from across the industry, the Tool will help firms document and assess AI use cases in line with the EU AI Act and other interdependent regulations, including GDPR, MiFIR and DORA, using a free-of-charge standardised tool.
The general application of the AI Act is set to enter into force next year—including new obligations for high-risk AI system providers.
EFAMA has submitted its response to ESMA’s consultation on the Active Account Requirements (AAR). Our industry stands ready to implement the AAR by June 2025... However, we have strong reservations about the heavy and redundant reporting requirements.
EFAMA has published its latest Monthly Statistical Release for November 2024.
European Commission’s Omnibus initiative should also be used to make CSRD consistent with SFDR
Today the European Securities and Markets Authorities (ESMA) hosted the T+1 Governance Launch Meeting to present the arrangements for driving the move to the reduction of default settlement cycles to T+1 for EU securities markets.
We appreciate the opportunity to respond to this important consultation and remain gladly at the disposal of the European Commission staff to elaborate on any of our responses.
Supervisory convergence is a core element of the Single Market and integral to removing barriers to cross-border provision of financial services. It is not enough to have a common rule book, but also the reading of those rules by supervisors and supervisory practices should converge to ensure the Single Market is not hampered by diverging interpretations and gold-plating of EU rules.
• EFAMA reiterates the European asset management industry’s strong support for the CMU project in all its dimensions. We welcome the range of initiatives, from the overarching aim of rebuilding confidence in financial markets by putting investors’ interests at the heart of the project, to the promotion of market-based financing of the economy, the development of a PEPP or the development of a comprehensive strategy on sustainable finance.
EFAMA is grateful for the opportunity to comment on the new OECD Public Discussion Draft on BEPS Action 6 and the treaty entitlement of non-CIV funds Discussion Draft on non-CIV examples. In addition EFAMA would like to make positive use of this opportunity and comment as well on the general situation of CIVs as well as of Non-CIVs against the background of the BEPS Action 6 implementation.
EFAMA welcomes the opportunity to respond to the EBA on its proposal for a new prudential regime for investment firms. As the EBA is aware, the activity of portfolio management on behalf of thirdparty clients broadly falls under three separate EU legal regimes:
i. Individual discretionary portfolio management performed by investment firms on a client-byclient basis, authorised under and complying with the Markets in Financial Instruments Directive, as per Annex I Section A, point 4 (as recently amended by MiFID II);

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