Over the year, ALFI participates in numerous consultations issued by European Institutions and industry associations.
ALFI comments on ESMA’s consultation paper on integrating sustainability risks and factors in the UCITS Directive and AIFMD- ALFI statements
On 19 February 2019, ALFI answered to ESMA’s consultation paper on integrating sustainability risks and factors in the UCITS Directive and AIFMD.
ALFI responded to the IOSCO Consultation on a proposed framework for assessing leverage in investment funds- ALFI statements
IOSCO closed the consultative period on 1 February 2019 for respondents to comment on the proposed framework to help measure leverage used by investment funds, which in some circumstances could pose financial stability risks.
ALFI response to ESMA Consultation on Draft Guidelines on Reporting under Article 37 of the Money Market Funds Regulation- ALFI statements
On 12 February 2019, ALFI responded to the ESMA Consultation on Draft Guidelines on the Reporting to Competent Authorities under Article 37 of the Money Market Funds Regulation.
On 6 December 2018, ALFI responded to the ESA consultation concerning targeted amendments to the PRIIPs KID.
Click here to read the document.
ALFI's Response to ESMA consultation on the extension of the clearing exemption for intragroup transactions with third countries- ALFI statements
ALFI published its response to ESMA consultation on the extension of the clearing exemption for intragroup transactions with third countries.
The European Commission published for comments in May a number of legislative proposals on sustainable finance as a follow-up to its Action Plan on sustainable finance.
On 26 June 2018, ALFI published its analysis of the two drafts issued by the European Commission amending the Delegated Regulation in relation to depositary safekeeping duties towards AIF and UCITS clients in case of delegation.
ALFI response for the Consultation Paper on the Amendments to the EMIR Clearing Obligation under the Securitisation Regulation- ALFI statements
On 15 June 2018, ALFI has published its response for the ESMA Consultation Paper on the Amendments to the EMIR Clearing Obligation under the Securitisation Regulation. Read the document here.
On 15 June 2018, ALFI has published its response to ESAs Consultation on Amendments to Delegated Regulation (EU) 2016/2251 on risk mitigation techniques for OTC-derivative contracts not cleared by a CCP under Article 11(15) of regulation (EU) No 648/2012 in the context of the STS securitisations under Regulation (EU) 2017/2402. Read the document here.
Following the publication of a new Double Tax Treaty between France and Luxembourg (the “DTT”), ALFI would like to comment on the features that have an impact on Luxembourg investment funds and the Luxembourg investment fund industry. ALFI appreciates that the DTT is however the product of a bilateral negotiation dealing with issues across a number of industries