This is a timely and necessary review to which we hope to contribute in a constructive manner. As already recognised in the consultation paper and in the MiFID Quick Fix proposal, RTS 27 and RTS 28 currently fall short of the objective of providing valuable and comparable datasets for investment managers and the investing public. We appreciate the present effort to revise reporting requirements to produce more meaningful reports.
Investment managers, acting on behalf of their retail and institutional clients, are among the largest investors in financial markets. They represent a key component of the market’s “buy-side” segment.
In representing the interests of its members on wholesale capital market issues, EFAMA advocates for fair, deep, liquid, and transparent capital markets, supported by properly regulated and supervised market infrastructure.
EFAMA’s response to ESMA’s Review of the MiFID II framework on best execution reports
Industry Approach to CSDR Settlement Discipline Regime
The Joint Associations1 welcome clarification from ESMA that national competent authorities are expected not to prioritise supervisory actions in relation to the application of the CSDR buy-in regime.2
Joint Statement on EU Commission proposal for revised Market in Financial Instrument Regulation (MiFIR)
We see great value in the creation of a consolidated tape to support Europe’s capital markets. However, we qualify that statement with a reminder that the framework for a successful consolidated tape should
i) address the known market failure around market data costs,
Cross-Industry Consensus on EU Equity Consolidated Tape
EFAMA, AFME, BVI and Cboe Europe Agree Cross-Industry Consensus on EU Equity Consolidated Tape
EU Equity Consolidated Tape Proposal - Statement of Principles
A Cross-Industry Consensus on the EU Equity Consolidated Tape Proposal - Statement of Principles
EFAMA, AFME, BVI and Cboe agreed on a set of 11 Principles.
The provision of an appropriately constructed EU Equities Consolidated Tape (“CT”) will democratise access to equities (as proposed by the EU Commission) for all investors, regardless of resources or sophistication, with a comprehensive and standardised view of EU equities prices.
EFAMA’s reply to ESMA’s consultation paper on the opinion on Trading Venue Perimeter
We welcome this opportunity to comment on a review of the TV perimeter, and support ESMA’s objective of clarifying when systems and facilities qualify as multilateral.
Annual Report 2016
Asset Management Report 2017
Closet Index Funds
EFAMA has reviewed ESMA’s statement “Supervisory work on potential index tracking”, which sets out research to determine whether any indication of closet indexing could be found at EU level. To contribute to the debate on this matter, EFAMA has prepared a paper, which highlights the limits of identifying closet index funds through a statistical analysis, drawing on recently published research papers.