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
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Announcement
Capital Markets
Capital Markets Union
Competitiveness
EU Fund regulation
International agenda
Investor Education
Management Companies
Sustainable Finance
Tax ＆ Accounting
10 November 2021
Thank you to the Investment Management Forum sponsors | Register now!
Register now for our Investment Management Forum next week! High-calibre panels and keynote speakers promise rich, informative and thought-provoking exchanges between European policymakers, investment managers and regulators on
- the Competitiveness of our industry
- the EU retail investment strategy
- the latest in global standards for sustainability reporting
- challenges and opportunities of alternative investment regulations
- the impact of digitalisation on asset management
- and more...
Press Release
Capital Markets
EMIR
MIFID
Capital Markets Union
Data
07 October 2021
Statement on the release of the Oliver Wyman study ‘Caught on Tape’
“Oliver Wyman’s study ‘Caught on Tape’ provides a perplexing take on Consolidated Tape for Europe. Sure enough, it starts with accurate observations: the high number of trading venues in Europe, the resultant fragmented liquidity, unseen liquidity due to the lack of a consolidated tape, and the fact that leading markets like the US and Canada today benefit from a real time consolidated tape.
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.
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
