EFAMA welcomes the opportunity of this consultation report to share views on how regulators could foster greater consistency in the management of liquidity risks in the Open-Ended Funds (OEFs) sector and on how the FSB should proceed in the future to evaluate any potential build-up of systemic risks in capital markets.
Environmental, social, and governance (ESG) considerations play a crucial role in asset managers' investment decisions for several reasons:
In July the European Commission released their long-awaited Retail Investment Strategy, including multiple proposals aimed at boosting retail participation in capital markets. EFAMA has provided comments on this in their ‘Have your say’ forum, where we briefly highlight some of our main concerns.
EFAMA responds to ESMA's Consultation Paper - From only 20 ELTIFs at the start of the review of the ELTIF Regulation in late 2021 to 95 as of August 2023, the launch of ELTIF products has significantly increased over the last three years, with further market growth expected in the years to come.
We strongly encourage ESMA to uphold the positive momentum of reforms initiated at Level 1 and guarantee that the requirements established by the draft RTS are conducive to the ongoing success of the ELTIF product.
EFAMA has joined together with the European Sustainable Investment Forum (Eurosif), the Principles for Responsible Investment (PRI), the Institutional Investors Group on Climate Change (IIGCC) and over 90 investors and financial market participants, to call on the European Commission to uphold the integrity and ambition of the first set of European Sustainability Reporting Standards (ESRS).
The draft ESRS Delegated Act presents several potential implications for investors and entails major inconsistencies across the Sustainable Finance legislative framework. In our policy paper we focus on the alignment of ESG reporting on two crucial areas: (1) the requirements of the Sustainable Finance Disclosure Regulation (SFDR), notably the Principal Adverse Impact indicators (PAIs), and (2) the Transition Plans and targets.
EFAMA has responded to the European Supervisory Authorities' (ESAs) joint consultation setting out various regulatory technical standards (RTS) for the Sustainable Finance Disclosure Regulation (SFDR). They propose new sustainability indicators in relation to principle adverse impacts (PAIs) and additional disclosures to the ‘do no significant harm’ principle, as well as some other modifications.
EFAMA offers a detailed view on the active accounts proposal in this paper. Costs to the end investor are broken down into two main buckets i) operational build-out and ii) in nominal terms the much larger impact of loss of netting efficiencies. Potential impacts on financial stability are also examined, with a focus on the widening basis which will result from large volumes of one-directional flows onto an EU-CCP. The impact on margins and procyclicality are also studied. The analysis points to increased liquidity risk for
EFAMA believes that IORPs should be able to invest in financial instruments traded in all third country markets where the latter meet certain conditions, regardless of the adoption of an equivalence decision by the Commission (...).
In our response to ESMA on its review of the guidelines on stress-testing parameters for Money Market Funds (MMFs), EFAMA cautions against using overly simplistic assumptions.
