EFAMA agrees in principle with many of ESMA’s suggested approaches in their consultation on guidelines on certain aspects of the MIFID II appropriateness and execution-only requirements.
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.
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.
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.
Following the publication of the European Commission report confirming the settlement discipline regime will be reviewed, Susan Yavari, Regulatory Affairs Adviser at EFAMA, commented:
Q #1 When will LIBOR phase out and which rates will be replacing it?
The appropriate construction, and conditions for the usage, of a Consolidated Tape
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.
"It gives me great pleasure to provide you with an overview of our activities since our Annual General Meeting in Paris last year. While we were very much looking forward to hosting you all in Brussels this week, the current crisis and associated travel restrictions has forced us to improvise and turn our meeting into a virtual AGM.