We disagree with an extension of its scope to UCITS’ and AIFs’ management companies to the scope of the reporting requirements imposed by MiFIR, Art. 26. This extension would be in breach of the principle of proportionality, as:
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
Distribution ＆ Client Disclosures
EU Fund regulation
UCITS
23 November 2020
EFAMA's reply to ESMA's CP on MiFIR Review report on the obligations to report transactions & reference data
Policy position
Capital Markets
14 September 2020
EFAMA comments EC CP on a Covid-19 Capital Markets Recovery Package
EFAMA appreciates the Commission's efforts in pursuing an alleviation of certain MiFID II requirements in the interest of promoting a swift recovery from the economic crisis precipitated by the Covid-19 pandemic (....).
EFAMA believes however that there are more effective ways to foster SME access to markets and urges the Commission to consider a set of further measures (...)
Policy position
Capital Markets
03 August 2020
EFAMA's response to ESMA's Call for evidence on the availability and use of credit rating information & data
Related news
Infographic
Capital Markets
MIFID
Capital Markets Union
Data
06 October 2021
Visual | Why do we need a real-time Consolidated Tape in the EU?
The current lack of quality pre- and post-trade data and the fragmentation of data sources remain an obstacle to the completion of the Capital Markets Union. The benefits of a real-time Consolidated Tape are wide-ranging: from market surveillance for supervisors, to best execution and an improved view on trading opportunities for retail investors, to portfolio management and pre- and post-trade analysis for fund managers to name a few.
Policy Position
Capital Markets
EMIR
16 September 2021
UK clearing house equivalence - request from nine trade associations
Nine associations (AFME, AIMA, EAPB, EBF, EFAMA, FIA, ICI, ISDA, SIFMA AMG) welcome the Commission's decision to grant a time-limited equivalence decision in respect of UK CCPs. However, when this time-limited equivalence decision expires on 30 June 2022, there remains a significant risk of disruption to clearing for EU firms and to their access to global markets.
Policy Position
Capital Markets
CSDR
15 July 2021
Joint association letter on the CSDR Settlement Discipline implementation timeline
On 14 July 2021, sixteen trade associations, representing buy-side, sell-side and market infrastructures, wrote to ESMA and the European Commission regarding the timeline for implementation of the mandatory buy-in rules as part of the CSDR Settlement Discipline Regime.
The Joint Associations welcome the Report from the Commission on the CSDR Review published in July 2021 and fully support the Commission’s intention to consider amendments to the mandatory buy-in regime, subject to an impact assessment.
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
Deputy Director, Capital Markets and Digital
