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.
Related policy positions
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
Policy position
Capital Markets
MIFID
14 February 2022
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.
Policy position
Capital Markets
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
Related news
Press Release
Capital Markets
21 February 2023
EFAMA statement on European exchanges’ bid to run a consolidated equities tape
EFAMA welcomes the recent proposal by European exchanges to build a consolidated tape. This affirms the buy-side’s long standing view that a European consolidated tape is key to completing the objectives of the Capital Markets Union and ensuring that European capital markets remain globally competitive. We have identified important use-cases for institutional and retail investors alike, not least in the ability to receive best execution on trades.
Press Release
Capital Markets
03 June 2022
EFAMA, ICSA & MFA welcome IOSCO Feedback Statement on “Market Data in the Secondary Equity Market”
3 June 2022 - EFAMA, ICSA and MFA (the Associations) have read IOSCO’s Feedback Statement on “Market Data in the Secondary Equity Market” following the IOSCO consultation in 2021, and warmly welcome its conclusions.
The Associations would like to draw attention towards the executive summary in particular, where a number of valuable insights and recommendations are presented. For example, we fully support the statement below, though we would suggest an important addition:
Press Release
Capital Markets
MIFID
30 May 2022
Cross-Industry Consensus on EU Equity Consolidated Tape
EFAMA, AFME, BVI and Cboe Europe Agree Cross-Industry Consensus on EU Equity Consolidated Tape
Monday 30 May, 2022 - AFME, BVI, Cboe Europe and EFAMA have today jointly published a position paper which provides a set of key principles needed to ensure the successful creation of an EU Equity Consolidated Tape (CT).
Related publications
Publication
Capital Markets
01 July 2025
Advancing EU capital markets: Prioritising key targets for the Savings and Investments Union
Publication
Capital Markets
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
