EFAMA firmly supports the Commission’s proposed amend of the ELTIF Regulation, in line with its recently revamped “new” CMU.
EU Fund regulation
The EU fund product landscape is deep, diverse and dynamic. Since the birth of the UCITS framework in 1985, European institutions have progressively refined it into a global “gold standard”, one that successfully balances strict regulatory requirements with the flexibility required by manager to meet evolving client demands. The successful evolution of UCITS was followed by the creation of alternative investment funds (AIFs) under the 2011 AIFM Directive, adding a second important pillar to EU fund/manager regulation. Building on this second pillar are further ambitious EU fund products, such as EUSEFs, EUVECAs and ELTIFs. EFAMA has helped guide all of these key regulatory developments, informing policymakers and regulators on their main merits and drawbacks, while also keeping a close eye on their respective review initiatives.
EFAMA strongly supports a fundamental review to the ELTIF regime, in view of broadening its eligible investment universe and adapting it to better meet retail investor needs. We are also closely monitoring the review of the AIFM Directive from a product regulation standpoint, including possible spillover effects on the UCITS Directive requirements. Further work involves keeping pace with relevant ESMA initiatives, such as the work around the Common Supervisory Action on costs and fees for UCITS.
EFAMA's response to the EC's public consultation on the review of ELTIF Regulatory Framework
EFAMA's reply to ESMA's CP on MiFIR Review report on the obligations to report transactions & reference data
We disagree with an extension of its scope to UCITS’ and AIFs’ management companies to the scope of the reporting requirements imposed by MiFIR, Art. 26. This extension would be in breach of the principle of proportionality, as:
EFAMA's response to ESMA's CP on Implementing technical Standards under Regulation (EU) 2019/1156
High-level response to ESMA consultation on notifications for cross-border marketing and management of AIFs and UCITS
EFAMA welcomes the European Securities and Market Authority’s continuous commitment to creating a single market for investment funds, confirmed by the draft regulatory standards currently under consideration. These RTS/ITS would further harmonise information that asset managers should provide to their national competent authorities before marketing or managing an investment fund on a cross-border basis, thus facilitating intra-EU product distribution.
EFAMA reply to EC targeted consultation on the functioning of the Money Market Fund Regulation
The European Fund and Asset Management Association (EFAMA) has published its response to the European Commission’s targeted consultation on the functioning of the EU Money Market Fund Regulation (MMFR).
US mutual funds are not necessarily cheaper than UCITS | EFAMA Market Insights Issue #8
EFAMA released today issue number eight of its Market Insights series titled 'The Costs of UCITS and US Mutual Funds - We can only compare like with like'.
EFC Categories Report
Fund Fees in Europe: TER Report
A report commissioned by the European Fund and Asset Management Association published on 4 October 2011 aims to give investors greater transparency and understanding of cost breakdown within the Total Expense Ratio ("TER") of European mutual funds.