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

Press Release

Distribution ＆ Client Disclosures

PRIIPs

24 November 2021

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.

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