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.
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.
Joint trade association letter regarding Implementation of CSDR SDR
EFAMA reply to ESMA CP on marketing communications guidelines
EFAMA believes that ESMA’s draft ‘marketing communication’ Guidelines still require important clarifications to ensure full alignment between them and MiFID II’s Commission Delegated Regulation Article 44. This alignment is essential to ensure coherent rules for fund management companies and distributors. Unfortunately, parts of the proposed Guidelines are overly prescriptive and may unintentionally make some marketing materials vaguer or even inconsistent with local MiFID requirements for distributors.
EFAMA's reply to EC's consultation on the Review of CSDR
EFAMA supports the main objectives of CSDR to increase the safety and efficiency of securities settlement, including:
- Shorter settlement periods,
- Prudential and supervisory requirements for CSDs and other institutions providing banking services ancillary to securities settlement,
- The imposition of a penalty regime under CSDR as an important step towards improving settlement efficiency in European capital markets.
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.
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.
Global Memo: Benchmark Data Costs
A key purpose of the financial system is to allocate capital and risk in a manner that supports sustainable economic development and growth, including through the provision of financing, investment and hedging products. Financial benchmarks/indices are fundamental to the functioning of financial markets and are widely used in both retail and wholesale markets. In particular, benchmarks are a valuable tool helping market participants to set prices, measure performances, or work out amounts payable under financial contracts or instruments.
3 questions to Agathi Pafili on CSDR
Q #1 What is the CSDR’s Settlement Discipline Regime (SDR) and what does it seek to achieve?
Asset Management in Europe - An Overview of the Asset Management Industry - November 2020
The report aims to provide a unique and comprehensive set of facts and figures on the state of the industry at the end of 2018 but also to highlight the fundamental role of asset managers in the financial system and wider economy.