EFAMA firstly wishes to commend the FSB’s change of focus in the course of 2015, from a proposed assessment methodology intended to identify non-bank, non-insurance globally systemically important financial institutions (NBNI G-SIFIs) to a revised and more objective focus on asset management activities. Although we understand the former framework may be revisited by the FSB once its Recommendations are finalised, we appreciate that certain key characteristics of the asset management industry have been recognised and well reflected in the present consultative document.

EFAMA is grateful for the opportunity to contribute to the drafting of the Regulation through a consultation and we appreciate the effort of the regulator to adopt an approach to reporting consistent with EMIR and to develop, where more efficient, a different reporting logic.

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.