EFAMA firstly wishes to commend the FSB’s change of focus in the course of 2015, from a proposed assessment methodology intended to identify non-bank, non-insurance globally systemically important financial institutions (NBNI G-SIFIs) to a revised and more objective focus on asset management activities. Although we understand the former framework may be revisited by the FSB once its Recommendations are finalised, we appreciate that certain key characteristics of the asset management industry have been recognised and well reflected in the present consultative document.
EFAMA reply to FSB consultation on proposed policy recommendations to address structural vulnerabilities from asset management activities
As a principle, EFAMA supports every effort made to enhance financial market regulation which reinforces the stability of the financial system, of which EMIR is an important part.
Prior to replying to the consultation, we wish to make the following general remarks.
Firstly, we fully support the points raised by ESMA that recognizes that several types of counterparties active in the OTC derivatives markets are facing numerous issues in relation to the access to central clearing due to:
European financial associations call for outstanding issues on PRIIPs Regulation to be addressed in the RTS
The European Banking Federation, Insurance Europe, the European Fund and Asset Management Association (EFAMA) and the European Structured Investment Products Association reconfirm their full support for the objectives of the PRIIPs initiative. In light of consumer protection, the PRIIP Key Information Document (KID) can be a valuable tool enabling retail investors to compare products and, hence, make informed investment decisions.