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.
EFAMA views and recommendations on ESMA's consultation on the review of EMIR RTS on APC margin measures
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.
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
Robust governance needed for future consolidated tape providers
ESMA technical standards move one step closer to consolidated tape launch.
ESMA recently closed the consultation for regulatory technical standards that will define the competitive selection process for the consolidated tape, as well as the technical abilities that applicants will be assessed on. In its response for the buy-side, EFAMA stressed that a robust governance framework for the operators of the tapes is critical.
Where there is a will, there is a way
This article was first published in Paperjam on 2 April 2024.
The Efama trade group has several recommendations on how to build stronger capital markets in Europe, and help individual investors at the same time.
Households continue to keep a disproportionate amount of money in bank deposits in most European countries
New report calls for action to be taken to revive the Capital Markets Union project
Advancing EU capital markets: Prioritising key targets for the Savings and Investments Union
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:
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.