EFAMA wholeheartedly supports ESMA’s objective of ensuring a consistent and harmonised application of the MiFID II product governance requirements. In our response to their consultation on the topic, we raised the following points:
Distribution & Client Disclosures
EFAMA monitors issues surrounding fund distribution and disclosures to investors. These include investor protection and disclosure issues arising from the evolving PRIIPs and MiFID frameworks, the shift towards digital distribution tools, and the continued integration of ESG considerations into fund products.
ESMA’s Consultation paper on the review of the guidelines on MiFID II product governance requirements
EU Commission targeted consultation on open finance framework and Data sharing in the financial sector
EFAMA appreciates the opportunity to comment on the European Commission's Targeted consultation on open finance framework and data sharing in the financial sector.
EFAMA welcomes the opportunity to respond to the EC’s targeted consultation on the functioning of the ESG rating market in the EU and on the consideration of ESG factors in credit ratings. Please note that our response covers, at the same time, ESG ratings and ESG data providers, as the demand for ESG “raw” data has been increasing at a steady pace. The use of ESG data has also rapidly shifted from a narrow set of investment products to being prolific across all investment products.
The European ESG Template (EET) is meant to facilitate the necessary exchange of data between product manufacturer and distributor for the purpose of fulfilling ESG-related regulatory requirements contained in the SFDR, relevant provisions of the Taxonomy Regulation, and the relevant delegated acts complementing MiFID II and IDD. The EET V1 is based on the regulatory situation on the day of publication and will be reviewed regularly depending on the evolving regulation, and at least confirmed annually. With regard to the MiFID target market, the EET interacts with the EMT V4.
The European PRIIPs Template v2.0 (EPT) incorporates the necessary changes based on the revised PRIIPs RTS, published by in the Official Journal of the European Union in December 2021.
The EPT is intended to be used for products sold from January 2023 onwards. It is important that data contained in the EPT is communicated by asset managers to insurers in good time before this date, bearing in mind any national market specificities.
▶️Find more details here: https://lnkd.in/dN_ZNU3C
EFAMA is recruiting a regulatory policy adviser in distribution of financial products, investor protection and/or client disclosures, as well as a regulatory policy adviser with relevant experience in sustainable finance and/or stewardship.
Please visit EuroBrussels for full details of the position and how to apply.
Funds face unique challenges in performing intermediary oversight, and especially so because of MiFID II requirements, changing regulatory landscapes, and the absence of an industry agreed-upon standard between funds and their distribution channels. To help address these challenges, a dedicated working group developed a uniform due diligence questionnaire (DDQ) that will serve as the standard for investment funds (UCITS and AIFs) in performing onboarding and ongoing oversight of distribution channels.