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.
EFAMA's reply to ESMA's CP on RTS specifying the scope of the consolidated tape for non-equity financial instruments
EFAMA supports every efforts made to enhance financial markets regulation which reinforces the stability and the transparency of the financial system.
In that perspective, EFAMA welcomes the opportunity to comment on the ESMA Consultation Paper on RTS specifying the scope of the consolidated tape for non-equity financial instruments. We consider that a consolidate tape (“CT”) is a key positive factor for price formation and transparency.
Prior to replying to the consultation, we wish to make the following general remarks
EFAMA welcomes the opportunity to respond to the European Commission’s Green Paper on retail financial services. Widening the opportunities for European citizens to save and invest will facilitate better outcomes both for savers and the wider European economy.
EFAMA fully shares the goals of a Single Market for retail financial services in the EU, i.e.:
1. Promoting an EU-wide market in retail financial services that can facilitate cross-border business and consumer choice.
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.
EFAMA appreciates the opportunity to respond to the IOSCO Retail Market Conduct Task Force's consultation on retail investment trends.
In our view, the IOSCO report provides a comprehensive picture of the retail market trends and risk magnifiers.
We also take the opportunity to share our views on the following areas:
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.