EFAMA replied to a specific question on moving to stage 3 for the determination of the liquidity assessment of bonds.
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 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.
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's response to the EU Commission's targeted consultation on options to enhance the suitability and appropriateness assessments
EFAMA appreciates the opportunity to share our views on the European Commission’s consultation on enhancements to the suitability and appropriateness assessments forming part of the wider, upcoming Retail Investment Strategy.
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
This is our 13th edition of the Asset Management in Europe report, which provides an in-depth analysis of recent trends in the European asset management industry, focussing on where investment funds and discretionary mandates are managed in Europe.
It gives me great pleasure to provide you with an overview of our activities since our Ordinary General Meeting of last year.
In support of our call for additional time to implement the PRIIPs rules, we have produced an infographic that summarises the challenges our members face replacing UCITS KIIDS with PRIIP KIDs. The infographic shows the many entities involved in the process and the steps required to prepare a PRIIP KID. Feel free to make use of this infographic.