The European Fund and Asset Management Association (EFAMA) welcomes the opportunity to respond to this important review of RTS 153/2013 and accompanying guidelines, in light of the procyclicality witnessed during the peak volatility of the Covid crisis. European CCPs already have standard anti-procyclicality tools in their rulebooks and this did lead to less volatile moves in margin in Europe versus other jurisdictions.
Capital markets
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.
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EFAMA views and recommendations on ESMA's consultation on the review of EMIR RTS on APC margin measures
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EFAMA position MiFIR review - a buy-side view on consolidated and market structure reforms
The European Commission’s proposal on MiFIR establishes the blueprint for a consolidated tape (CT) for Europe’s capital markets. It also significantly alters the competitive market structure brought about by MiFID II by introducing greater transparency requirements. Finally, it addresses important issues around market data costs.
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27 January 2022
IOSCO Consultation on 'Review of margining practices'
We commend the work that IOSCO has undertaken to date on this topic including the survey work and the summary findings in the form of the report currently under review. It is fair to say that the conclusions of the report and areas for further work gave rise to detailed discussions within our industry, yielding ultimately firm views on the priority areas that we support and see value in, and areas we felt were not reflected in the study and thereby building risk into margining models in future crisis scenarios. These areas are fur
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14 June 2021
Joint statement by EFAMA and EFSA on Consolidated Tape and market data costs
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Key recommendations for fair benchmark data costs - EFAMA/ICSA Global Memo on Benchmark Data Costs
EFAMA (European Fund of Asset Management Associations) and ICSA (International Council of Securities Association) published today a Global Memo on Benchmark Data Costs, identifying the main challenges arising from the increased use of benchmark data over recent decades and the imposition of increasingly complex and ove
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Joint trade association letter regarding Implementation of CSDR SDR
On 11 March 2021, EFAMA and 14 trade associations representing a wide range of stakeholders in the European and global financial markets wrote to the European Commission and ESMA raising concerns about the implementation of the mandatory buy-in requirement under the EU’s CSDR Settlement Discipline Regime.
Related publications
Publication
Capital Markets
01 July 2025
Advancing EU capital markets: Prioritising key targets for the Savings and Investments Union
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Capital Markets Union
Retail Investment
22 January 2024
Household Participation in Capital Markets
This report analyses the progress made in recent years by European households in allocating more of their financial wealth to capital market instruments (pension plans, life insurance, investment funds, debt securities and listed shares) and less in cash and bank deposits. It also includes policy recommendations on improving retail participation in capital markets, including for the Retail Investment Strategy currently under discussion.
Some key findings include:
Publication
Capital Markets
MIFID
16 November 2021
Buy-side use-cases for a real-time consolidated tape
A real-time consolidated tape, provided it is made available at a reasonable cost, will bring many benefits to European capital markets. A complete and consistent view of market-wide prices and trading volumes is necessary for any market, though this is especially true for the EU where trading is fragmented across a large number of trading venues. A real-time consolidated tape should cover equities and bonds, delivering data in ‘as close to real-time as technically possible’ after receipt of the data from the different trade venues.
Contact
Deputy Director, Capital Markets and Digital
