Nine associations (AFME, AIMA, EAPB, EBF, EFAMA, FIA, ICI, ISDA, SIFMA AMG) welcome the Commission's decision to grant a time-limited equivalence decision in respect of UK CCPs. However, when this time-limited equivalence decision expires on 30 June 2022, there remains a significant risk of disruption to clearing for EU firms and to their access to global markets.

Given the increasingly important role ESG ratings and data products providers play in investment processes, EFAMA welcomes the increased attention of regulators to this issue. In light of the growing regulatory scrutiny on the ESG characteristics of potential investments, improving the usability and reliability of the ESG ratings and data products is a key priority for the European asset management industry.

The Commission is trying to understand how the EU legal framework could be improved to tackle the use of legal entities with no or minimum substance and no real economic activities, by taxpayers operating cross-border to reduce their tax liability.

While cognisant of the FSB’s strict timelines in view of upcoming G20 summits, these should not come at the expense of a necessary and more informed debate on the causes at the root of last year’s stresses in global short-term funding markets (STFMs) and on ways to remedy these in the future. In fact, the options presented in the consultation report appear hurried and dismissive of critical facts, calling therefore for a deeper engagement with the global financial and investing community at large. 

EFAMA welcomes IOSCO's enhanced attention to transparency efforts supporting informed and qualified investment decisions in sustainability-related products. We support the adoption of such recommendations at the international level and believe IOSCO should leverage the experience with SFDR and Taxonomy in Europe to help establish consistent international standards, definitions and best practices.

In this response, we would like to highlight three pressing challenges deserving greater attention in the report from asset managers' perspective.