EFAMA welcomes ESMA’s Call for Evidence on asset segregation and custody services as a precious occasion to confirm our previous key messages - as per our response to the previous consultation around Guidelines on asset segregation under the AIFMD of December 2014 – and to clarify our position on new aspects of ESMA’s work.
UCITS
UCITS (Undertakings for Collective Investment in Transferable Securities) refers to the EU framework for harmonising the creation, management and marketing of collective investment schemes in the EU (and EEA) Member States. It places a strong focus on investors’ protection and product regulation. Owing to this harmonised framework, once UCITS funds are registered in one Member State, they can be freely marketed across the European Union. Initially adopted in 1985, the UCITS Directive has since been modified repeatedly, to take into account developments in financial markets.
EFAMA is adamant to protect the competitiveness and international appeal of UCITS.
EFAMA response to ESMA Call for Evidence on asset segregation
EFAMA response to Green Paper on Retail Financial Services
EFAMA welcomes the opportunity to respond to the European Commission’s Green Paper on retail financial services. Widening the opportunities for European citizens to save and invest will facilitate better outcomes both for savers and the wider European economy.
EFAMA fully shares the goals of a Single Market for retail financial services in the EU, i.e.:
1. Promoting an EU-wide market in retail financial services that can facilitate cross-border business and consumer choice.
EFAMA response to EC consultation on impacts of maximum remuneration ratio under CRD IV
Our corporate members are both subsidiaries of an EEA parent that is a credit institution as per Article 4(1)(1) of the CRR, or stand-alone investment firms as per Article 4(1)(2) of the CRR. Both types of entities risk becoming subject to the Maximum Ratio Rule as asset management companies licensed under either a UCITS or AIFM management company license, or licensed as investment firms under the MiFID regime to provide discretionary portfolio management services on a client-by-client basis.
A like-for-like comparison of the cost of US mutual funds and UCITS is missing from the latest ESMA report
In its recently published market report on the costs and performance of EU retail investment products, ESMA asserts that there are “substantial differences in the fund cost level between the EU and the US”. In its accompanying press release, ESMA emphasizes that “the market inefficiencies revealed by this higher cost level show the need to focus on the competitiveness of EU markets, within a future Savings and Investments Union.”
Industry sector matters when comparing the performance of active vs. passive equity UCITS
EFAMA has published today the latest edition of its Market Insights series, titled “The sectoral performance of active and passive UCITS - is a simple measure enough?”. This publication compares the net performance of different categories of equity UCITS funds over the last ten years (2014-2023).
Fund manager discretion is key for the best use of liquidity management tools
EFAMA responded to ESMA’s consultations on regulatory technical standards and guidelines, which aim to provide EU asset managers with further details on a broad and harmonised list of liquidity management tools (LMTs). As part of the recent AIFMD and UCITS review, these improvements will support our industry’s response to liquidity pressures, both in normal and stressed market conditions, while also protecting the interests of investors.
EFAMA Market Insights | Issue #1 | Net outflows from UCITS in March 2020 - Industry weathers Covid-19 crisis
The Covid-19 pandemic significantly impacted financial markets. Stock markets across the world suffered a steep decline driven by lower economic growth and corporate profits. As anticipated, the crisis caused substantial net outflows from UCITS in March (EUR 313 billion). However, as a percentage of net assets, these outflows were no higher than in October 2008, at the height of the global financial crisis (2.9%).
AMIC EFAMA Report - Managing fund liquidity risk in Europe - 2020
In 2019, AMIC and EFAMA decided to update their 2016 report “Managing Fund Liquidity Risk in Europe” following important policy and regulatory developments at EU and international levels. The purpose of this updated report is to outline the practical liquidity risk management processes which fund management companies put in place when setting up a fund and implement throughout the life of the fund. Also, the report describes the existing European and international regulatory frameworks in the area of fund liquidity risk management.