EFAMA welcomes the IOSCO Consultation report which we believe is a good starting point for further engagement with our industry on dilution in Open-Ended Funds (OEFs). We believe that dilution may indeed trigger investor protection concerns for certain funds and welcome, in this respect, IOSCO’s commitment to protect end-investors from material dilution. This being said, we however do not support the consultation report’s significant emphasis on financial stability considerations. Although liquidity risk management can support the resilience of a fund and, thus, the robustness of the broader sector, it would be unsubstantiated and disproportionate to derive the conclusion that fund liquidity risks would inevitably lead to financial stability ones. (more)