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.

Related policy positions

Policy position

Capital Markets

MIFID

Distribution ＆ Client Disclosures

11 June 2021

MiFID: EFAMA replies to ESMA consultation on RTS 2 Annual Review

EFAMA replied to a specific question on moving to stage 3 for the determination of the liquidity assessment of bonds.

Policy position

Capital Markets

MIFID

Distribution ＆ Client Disclosures

29 April 2021

ESMA consults on guidelines of the MIFID II appropriateness and execution-only requirements

EFAMA agrees in principle with many of ESMA’s suggested approaches in their consultation on guidelines on certain aspects of the MIFID II appropriateness and execution-only requirements.

Policy position

Distribution ＆ Client Disclosures

PRIIPs

26 April 2021

EFAMA asks for sufficient time to implement the new PRIIPs rules

EFAMA welcomes the ESAs’ official approval of the revised PRIIPs RTS and is now awaiting the Commission’s endorsement to have the RTS approved by the European co-legislators.

Originally, the Commission had intended to endorse the revised RTS by Q1 2020. With less than nine months remaining until the 31 December 2021 implementation deadline, there is now simply not enough time for fund managers and other product manufacturers to properly implement the envisaged wide-ranging changes. We explain why in more detail below.

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.

Policy Position

Distribution ＆ Client Disclosures

Retail Investment

24 May 2022

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:

Policy Position

Distribution ＆ Client Disclosures

27 April 2022

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.