We welcome yesterday's vote by the European Parliament plenary formally adopting two ‘quick fixes’ for PRIIPs (Packaged retail investments and insurance-based products) and UCITS (Undertakings for Collective Investment in Transferable Securities).
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.
European Parliament votes on ‘quick fixes’ for PRIIPs and UCITS - EFAMA statement
EFAMA Statement on the ECON Committee’s draft report amending the UCITS directive for PRIIPs
Andreas Stepnitzka, EFAMA Deputy Director, Regulatory Policy, comments:
Distance marketing of consumer financial services – Review of EU rules
EFAMA provided high-level comments to the Commission’s consultation on the potential review of the Directive on Distance Marketing of Consumer Financial Services.
We agree with the Commission’s interpretation that the Directive is seen as a “safety net” for financial services not already subject to product-specific legislation. Fund and asset managers are already subject to various, more stringent and detailed sectoral legislations, such as (but not limited to) UCITS, AIFMD and MiFID as well as the (more recent) Cross-Border Fund Distribution Directives.
EFAMA response to EC CfE ESG ratings and sustainability risks in credit ratings
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.
IOSCO Retail Market Conduct Task Force Report
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:
EFAMA response to ESMA’S consultation paper “guidelines on certain aspects of the Mifid II Suitability Requirements”
EFAMA places huge importance on this revision of ESMA’s suitability guidelines, as they spell out in detail how investors can invest in sustainable investment products. If they are well designed, the guidelines have the potential to significantly boost capital flows towards sustainable investments; a goal that the European fund industry strongly supports.
Investment Funds Distributor Due Diligence Questionnaire
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.