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:
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.
Our comment paper confutes the ECB study’s main findings by focusing on its two core areas, namely
liquidity and counterparty risks inherent to the structure and functioning of ETFs. A final section
considers the merits of further regulatory action addressed at the European ETF industry.
EFAMA has released its latest Market Insights report titled “Perspective on the costs of UCITS”. The full report breaks down the costs of UCITS, focusing on the fees charged for the different services provided along the investment fund value chain and
While cognisant of the FSB’s strict timelines in view of upcoming G20 summits, these should not come at the expense of a necessary and more informed debate on the causes at the root of last year’s stresses in global short-term funding markets (STFMs) and on ways to remedy these in the future. In fact, the options presented in the consultation report appear hurried and dismissive of critical facts, calling therefore for a deeper engagement with the global financial and investing community at large.
EFAMA wholeheartedly supports a retail investment strategy that gives EU citizens the necessary tools and the confidence to put their savings to work by investing in capital markets.
The growth in MMF net assets occurred against the backdrop of resolute actions by governments and monetary authorities
across the world to mitigate the impact of the Covid-19 crisis.
The European Fund Classification (EFC) is a pan-European classification system of investment funds, which is maintained by a Task Force of EFAMA.