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:
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.
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:
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 (...)
EFAMA has submitted its
response to the European Commission's consultations on the review of the MIFID II / MIFIR regulatory framework, where it has outlined its recommendations on investor protection and capital markets and infrastructure.
EFAMA's Director General Tanguy van de Werve commented: