EFAMA welcomes the opportunity to provide comments to the ESMA Consultation Paper on the technical advice to the European Commission on the Benchmarks Regulation. EFAMA also welcomes a number of clarifications and improved points that ESMA is providing in its Consultation and draft Technical Advice since its previous Discussion Paper.

EFAMA strongly supports the objective to provide retail investors with a key information document (KID) for all packaged retail and insurance-based investment products (PRIIPs). It is important that investors and their advisers throughout Europe are given meaningful, comprehensible and comparable information to feel confident about investing and to make sound investment decisions.

This memo covers investments in collective investment vehicles (CIV) in contractual, trust, or corporate form (simply referred as funds) from corporate and institutional investors acting on their own account (e.g. banks, life insurers, industry companies, etc.) and the accounting treatment of such investments under the upcoming IRFS 9 rules. While IFRS 9 contains many positive evolutions, many of our members have been warned by their client investors that IFRS 9 would change their attitude towards investing in funds.