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 EIOPA’s consultation and the opportunity to share our views on EIOPA’s recommendations to develop an EU single market for personal pensions.

EFAMA supports the conclusions of EIOPA’s impact assessment:

• The standardization of key elements of a PEPP - as proposed by EIOPA in its advice - with space to accommodate the specificities of Member States, is the best policy option.

• It would be difficult to achieve full standardization via harmonization because this would require bringing all national regulations on PPPs to one level.

EFAMA fully supports the aim of eliminating tax abuse enshrined in the draft Anti-Tax Avoidance (ATA) Directive which the European Commission published on 28 January 2016. EFAMA is the representative association for the European investment management industry. EFAMA represents through its 26 member associations and 61 corporate members EUR 21 trillion in assets under management of which EUR 12.6 trillion managed by 56,000 investment funds at end 2015.