EFAMA commented on IASB’s ED on IAS 12 (Pillar Two Model Rules). As the model rules drafted by the OECD establish that investment funds and investment entities should be carved out / excluded from Pillar Two, at first glance we expect them would not have a significant impact on our industry (at least on the strict product/funds side). While it is still to be confirmed what will be required from asset management firms and investors investing in funds to comply with the new rules, it is clear the analysis is highly complex.

EFAMA replied to IASB’s request for information on the Post-Implementation Review (PIR) of IFRS 9 – Classification and measurement. Our paper recaps EFAMA’s key concerns and recommendations to the IASB. The key concerns of the industry are the removal of recycling (in particular for institutional investors) and the classification of investment entities and investment funds as debt instruments.

EFAMA comments the IASB's Exposure Draft (ED/2017/7). It supports IASB's efforts to improve consistency in the layout of the primary financial statements and the relevance of financial statements.

Proposals around new defined sub-totals and line items will improve consistency and will assist in the implementation of electronic reporting format initiatives.

This memo covers investments in collective investment vehicles (CIV) in contractual, trust, or corporate form (simply referred as funds) from corporate and institutional investors acting on their own account (e.g. banks, life insurers, industry companies, etc.) and the accounting treatment of such investments under the upcoming IRFS 9 rules. While IFRS 9 contains many positive evolutions, many of our members have been warned by their client investors that IFRS 9 would change their attitude towards investing in funds.

EFAMA is grateful for the opportunity to comment on the OECD Public Discussion Draft related to concerns received by the OECD on previous discussion drafts related to the Report on Action 6, as to how the new provisions included in the Report on Action 6 could affect the treaty-entitlement of nonCIVs. We agree with the aim of the discussion draft to clarify any concerns in relation to the discussion concerning the treaty entitlement of CIVs / Non-CIVs.