EFAMA welcomes the opportunity to respond to the EC’s targeted consultation on the EU’s central clearing framework. We are pleased to find in this consultation document a fair reflection of the complexity of the CCP ecosystem and consistency with the issues raised in previous dialogues held with the European Commission. In that same spirit, we hope in our response to provide feedback that resonates with the EC’s broader policy objectives while minimizing systemic risk and undue harm to our industry.
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
EU Com targeted consultation on the review of the central clearing framework in the EU
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
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.
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.
Related news
Policy Position
Capital Markets
CSDR
12 March 2021
Joint trade association letter regarding Implementation of CSDR SDR
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.
Publication
Capital Markets
CSDR
05 March 2021
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?
Press Release
Capital Markets
Capital Markets Union
Data
03 November 2020
An appropriately constructed Consolidated Tape could help to build deeper and more open capital markets in Europe
EFAMA and EFSA welcome the publication of a Market Structure Partners Study on the Creation of an EU Consolidated Tape which addresses the challenges, demand, benefits and proposed architecture for consolidating European financial market data.
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
