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.
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.
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.
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:
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.