This article was first published in the 23rd edition of the Fact Book on 24 June 2025.
This article was first published in the 23rd edition of the Fact Book on 24 June 2025.
This article was first published in the 23rd edition of the Fact Book on 24 June 2025.
This article was first published in the 23rd edition of the Fact Book on 24 June 2025.
Given the emphasis on costs and value for money for European investors, we have examined whether lower fees consistently translate into better net performance. Our analysis shows that this is not always the case; less-expensive funds do not necessarily deliver the highest returns, and in some instances, higher-cost funds outperform.
This article was first published in the 23rd edition of the Fact Book on 24 June 2025.
This article was first published in the 23rd edition of the Fact Book on 24 June 2025.
This article was first published in the 23rd edition of the Fact Book on 24 June 2025.
It has now been three years since the European Commission launched a consultation on the Open Finance framework, with the idea of creating a similar solution to PSD2 for a broader range of financial data. This initiative took the shape of the Financial Data Access Regulation (FiDA)1, with the proposal being published in June 2023.
M&G Investments Europe’s CEO, Micaela Forelli, to become Vice-President
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.
EFAMA, the voice of the European investment management industry, believes that, for retail clients, standardised disclosure of information can improve the comparability of financial products that promote environmental and/or social characteristics or have a sustainable objective. It will also contribute to the broader policy objectives of the Sustainable Finance Disclosures Regulation (SFDR) to enhance transparency towards end-investors, hold market participants accountable and fight greenwashing.

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