EFAMA appreciates the opportunity to comment on the EMIR 3.0 proposal reforming the clearing framework in the EU. We share the objectives of this review which seek to ensure financial stability in the EU, and the well-functioning of the existing central clearing framework. We understand the objective to reduce excessive exposure to substantially systemic CCPs over time, though we maintain that any regulatory measures should be proportionate to the regulatory rationale, and should not unduly harm market participants.
21 March 2023
Mandated levels of EU Clearing run counter to competitive and efficient clearing systems
Tax ＆ Accounting
10 March 2023
IASB ED on IAS 12 – Pillar Two Model Rules
EFAMA commented on IASB’s ED on IAS 12 (Pillar Two Model Rules). As the model rules drafted by the OECD establish that investment funds and investment entities should be carved out / excluded from Pillar Two, at first glance we expect them would not have a significant impact on our industry (at least on the strict product/funds side).
01 March 2023
Joint trade association advocacy paper on equity option margin exemption under EMIR 3
Sustainability-related Disclosures (SFDR)
21 February 2023
EFAMA response to ESMA Consultation on fund names using ESG terms
EFAMA welcomes ESMA's consultation paper on guidelines on funds’ names using ESG or sustainability-related terms. We support the overarching objective to promote transparency and tackle the risk of greenwashing by ensuring that investors are protected against unsubstantiated or exaggerated sustainability claims.