EFAMA believes that the general assessment of the characteristics of automated financial advice tools is captured accurately.
EFAMA believes that the general assessment of the characteristics of automated financial advice tools is captured accurately.
The signatories share the following views:
• Securitisation is an important element of well-functioning financial markets. Prudently deployed and sensibly regulated, it can:
o act as a bridge between the banks’ financing and the capital markets;
o enable non-banks to diversify funding sources; and
o provide investors with high quality fixed income securities at attractive yields.
EFAMA is supportive of the general objectives of the PRIIP KID Regulation. We are however concerned about the very limited time that product manufacturers will have between the final technical rules (RTS) and essential guidelines being published and the deadline to produce Key Information Documents (KIDs) from 31 December 2016 onwards. Having provided extensive feedback throughout the ongoing Level-2 work, we seriously doubt there will be enough time for market participants to implement the final rules by the end of this year, as originally foreseen by the co-legislators.
EFAMA welcomes the opportunity to provide the views of the asset management industry to this challenging exercise of assessing the impacts of recent regulatory reforms in the area of financial services.
There are a number of general remarks that we would like to make by way of introduction.
Need for consistency and coordination