We appreciate the opportunity to respond to this important consultation and remain gladly at the disposal of the European Commission staff to elaborate on any of our responses.

EFAMA is closely monitoring the recent regulatory developments in the field of anti-money laundering and counter-terrorist financing, in particular the due diligence duties of the asset management sector. EFAMA is embracing the objective of enhancing transparency and accessibility to the beneficial ownership information and also fully acknowledges the importance of obtaining accurate identification and verification data of natural and legal persons for fighting money laundering and terrorist financing.

EFAMA supports every efforts made to enhance financial markets regulation which reinforces the stability and the transparency of the financial system.

In that perspective, EFAMA welcomes the opportunity to comment on the ESMA Consultation Paper on RTS specifying the scope of the consolidated tape for non-equity financial instruments. We consider that a consolidate tape (“CT”) is a key positive factor for price formation and transparency.

Prior to replying to the consultation, we wish to make the following general remarks

EFAMA supports every efforts made to enhance financial markets regulation which reinforces the stability and the transparency of the financial system.

In that perspective, EFAMA welcomes the opportunity to comment on the ESMA consultation paper on the Draft RTS and ITS under SFTR and amendments to related EMIR RTS.

Prior to replying to the consultation, we wish to make the following general remarks

Investors, originators issuers and other market participants represented by the above signatories are committed to supporting a safe and sustainable securitisation market that serves the real economy in Europe.

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.

The signatories share the following views:

• Securitisation is an important element of well-functioning financial markets. Prudently deployed and sensibly regulated, it can:

o act as a bridge between the banks’ financing and the capital markets;

o enable non-banks to diversify funding sources; and

o provide investors with high quality fixed income securities at attractive yields.