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

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.

Policy Position

Distribution ＆ Client Disclosures

22 March 2022

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.

Policy position

Distribution ＆ Client Disclosures

PRIIPs

15 December 2021

EFAMA response to ESA’s Joint Committee call for evidence on PRIIPs

EFAMA continues to support the overarching aim of the PRIIP KID as a single pre-disclosure document for all types of investment products.

EFAMA believes that the ESAs Joint Call for Evidence on PRIIPs and any subsequent proposals for revision of the PRIIPs Regulation should come after assessing in practice the revised PRIIPs RTS to be implemented from 31 December 2022, both to retail AIFs and UCITS.

European Parliament votes on ‘quick fixes’ for PRIIPs and UCITS - EFAMA statement

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).

Press Release

Distribution ＆ Client Disclosures

PRIIPs

22 October 2021

EFAMA Statement on the ECON Committee’s draft report amending the UCITS directive for PRIIPs

Andreas Stepnitzka, EFAMA Deputy Director, Regulatory Policy, comments:

Policy Position

Distribution ＆ Client Disclosures

Management Companies

29 September 2021

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.

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Related publications

Publication

MIFID

Distribution ＆ Client Disclosures

PRIIPs

Management Companies

AIFMD

03 June 2020

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.

Publication