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.
ESMA’s call for evidence on the integration of ESG preferences on suitability and product governance arrangements
EC "HAVE YOUR SAY" consultation on the EU Strategy for Retail Investors
In July the European Commission released their long-awaited Retail Investment Strategy, including multiple proposals aimed at boosting retail participation in capital markets. EFAMA has provided comments on this in their ‘Have your say’ forum, where we briefly highlight some of our main concerns.
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.
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:
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 response to EC CfE ESG ratings and sustainability risks in credit ratings
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.