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.

Joint Industry letter on the importance of advice and preserving the commission-based model

EFAMA, together with EBF, Insurance Europe, EACB, EAPB, ESBG and EUSIPA, issued a public letter addressed to Vice-President Dombrovskis, Commissioners McGuinness and Director-General Berrigan, remarking the importance of advice for European retail investors and the need to maintain the coexistence of fee-based and commission-based advice.

Policy Position

Distribution ＆ Client Disclosures

Retail Investment

10 October 2022

ESMA’s Consultation paper on the review of the guidelines on MiFID II product governance requirements

EFAMA wholeheartedly supports ESMA’s objective of ensuring a consistent and harmonised application of the MiFID II product governance requirements. In our response to their consultation on the topic, we raised the following points:

Policy Position

Distribution ＆ Client Disclosures

Retail Investment

07 July 2022

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.

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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