European asset managers welcome the joint statement from the European Commission, ESMA and the ECB putting a firm foot forward, and ‘accelerating the technical work’ needed to prepare the EU’s T1 transition
European asset managers welcome the joint statement from the European Commission, ESMA and the ECB putting a firm foot forward, and ‘accelerating the technical work’ needed to prepare the EU’s T1 transition
The European T+1 Industry Task Force, comprising 21 trade associations involved in European capital markets, was established in 2023 to bring together a diverse group of industry stakeholders who would be impacted by a move to a default T+1 settlement cycle for securities traded and settled in the EU.
EFAMA has released a joint statement together with AFME (Association for Financial Markets in Europe), EFSA and the Nordic Securities Association on significant issues with the supervision of market data costs.

Clarification is urgently needed to enable rather than restrict EU sustainable investment
The EU has been at the forefront of green bond issuances, demonstrating strong growth and commitment to sustainable finance. However, ESMA’s new Fund Naming Guidelines create inconsistencies with other sustainable finance regulations, like the EU Green Bond Standard, which could hamper the growth of the corporate green bond sector.
The Associations fully support ESMA’s aim of providing for an adequate level of transparency. This will be beneficial to investors, liquidity providers, other intermediaries, as well as issuers, across the entire range of different and diverse bond classes.
EFAMA publishes its latest Monthly Statistical Release for July 2024.
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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