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.
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.
Related policy positions
Policy Position
Capital Markets
MIFID
02 May 2022
EFAMA’s reply to ESMA’s consultation paper on the opinion on Trading Venue Perimeter
Policy position
Capital Markets
EMIR
08 April 2022
EU Com targeted consultation on the review of the central clearing framework in the EU
EFAMA welcomes the opportunity to respond to the EC’s targeted consultation on the EU’s central clearing framework. We are pleased to find in this consultation document a fair reflection of the complexity of the CCP ecosystem and consistency with the issues raised in previous dialogues held with the European Commission. In that same spirit, we hope in our response to provide feedback that resonates with the EC’s broader policy objectives while minimizing systemic risk and undue harm to our industry.
Policy Position
Capital Markets
EMIR
08 April 2022
EFAMA views and recommendations on ESMA's consultation on the review of EMIR RTS on APC margin measures
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.
Related news
Policy Position
Capital Markets
CSDR
22 December 2021
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
Policy Position
Capital Markets
MIFID
15 December 2021
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,
Press Release
Capital Markets
MIFID
Capital Markets Union
25 November 2021
EFAMA welcomes proposal on affordable consolidated tape - The association continues to urge action on market data costs
EFAMA is pleased to read today the details of a robust MiFIR proposal from the European Commission addressing key areas of reform around the creation of a consolidated tape (CT), along with adjustments to transparency requirements on trading.
Related publications
Publication
Capital Markets
Capital Markets Union
Distribution ＆ Client Disclosures
EU Fund regulation
Management Companies
23 June 2017
Annual Report 2016
Publication
Capital Markets
Capital Markets Union
Competitiveness
EU Fund regulation
International agenda
Management Companies
AIFMD
Tax ＆ Accounting
24 May 2017
Asset Management Report 2017
Publication
Capital Markets
Benchmarks
Management Companies
Supervision
26 July 2016
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.
Contact
Senior Regulatory Policy Advisor
