In a letter to policymakers, 18 European buy-side firms state that only an Equities/ETFs tape that delivers data in real-time and that includes pre-trade data in the form of 5 layers of best bid and offer, will meet with the necessary market demand to make the Equities/ETFs Consolidated Tape commercially viable. A reasonably priced tape is also a precondition for success, they argue.
EFAMA comments the European Commission's ViDA Proposal and welcomes the consistency of the proposal and the fact that VAT-exempt services will not be covered by the new DDR. With this solution, the proposal should allow tax authorities to focus on the real risk of tax fraud cases and should not create new burdensome procedures/compliance obligations that would represent new costs that in the end would be imposed on clients/consumers (e.g. end investors) for no reason.
EFAMA appreciates the opportunity to comment on the EMIR 3.0 proposal reforming the clearing framework in the EU. We share the objectives of this review which seek to ensure financial stability in the EU, and the well-functioning of the existing central clearing framework. We understand the objective to reduce excessive exposure to substantially systemic CCPs over time, though we maintain that any regulatory measures should be proportionate to the regulatory rationale, and should not unduly harm market participants.
EFAMA welcomes ESMA's consultation paper on guidelines on funds’ names using ESG or sustainability-related terms. We support the overarching objective to promote transparency and tackle the risk of greenwashing by ensuring that investors are protected against unsubstantiated or exaggerated sustainability claims.
The MiFID/MiFIR review will be key to the future success and competitiveness of the EU's capital markets.
With international competition for investment heating up markedly, European legislators need to ensure that EU regulation is helping, and not hindering, capital market growth and participation.
Various European trade associations representing EU capital markets, including EFAMA, BVI, EFSA and NSA, have published a letter outlining their main priorities for the review. This includes the following core elements:
In an environment with unclear definitions at EU level on key sustainable finance concepts, as well as a lack of complete, comparable and transparent ESG data, all market actors are concerned about the risk of greenwashing.
EFAMA commends the efforts of the Czech Presidency and Member States in reaching an agreement on the review of MiFIR/MiFID. EFAMA members welcome the Council position which unequivocally comes down on the side of competitive, globally attractive markets, driven by diversity and innovation and the right tools and infrastructures to support the retail investor.
EFAMA, together with EBF, Insurance Europe, EACB, EAPB, ESBG and EUSIPA, issued a public letter addressed to Vice-President Dombrovskis, Commissioners McGuinness and Director-General Berrigan, remarking the importance of advice for European retail investors and the need to maintain the coexistence of fee-based and commission-based advice.
EFAMA wholeheartedly supports ESMA’s objective of ensuring a consistent and harmonised application of the MiFID II product governance requirements. In our response to their consultation on the topic, we raised the following points:
