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.
EFAMA Statement on the ECON Committee’s draft report amending the UCITS directive for PRIIPs
Andreas Stepnitzka, EFAMA Deputy Director, Regulatory Policy, comments:
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.
Industry calls for reasonable implementation timeline for PRIIPs changes
EFAMA and several other financial industry associations, raised concerns in response to a consultation conducted by the European Commission on planned changes to the Packaged Retail and Insurance-based Investment Products (PRIIPs) framework.
The unexpected delay to the adoption of the revised PRIIPs RTS cuts the implementation period for the industry by more than two months. This leaves PRIIPs manufacturers and distributors with a too short period instead of the original timeframe of 12 months to implement the new rules.
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.