Over the year, ALFI participates in numerous consultations issued by European Institutions and industry associations.
On 27 March 2015, the Luxembourg draft law on FATCA was submitted to Parliament. The law will ratify the execution of the Intergovernmental Agreement (IGA) signed between Luxembourg and the United States of America on 28 March 2014 as well as the related Appendices and Memorandum of Understanding. It is expected that the law will be passed in the coming days. In this context, ALFI's implementation working groups for FATCA prepared a Q&A document to deal specifically with reporting and withholding issues in the context of FATCA.
ALFI response to EBA consultation paper on draft EBA guidelines on limits on exposures to shadow banking entities- ALFI statements
On 19 June 2015 ALFI responded to the EBA consultation paper on draft guidelines on limits on exposures to shadow banking entities. The EBA proposes, in the absence of a definition of “shadow banking entities”, to include alternative investment funds and money market funds under the definition of shadow banking entities which carry out banking activites outside a regulated framework. To read the full response please click here.
On 4 June 2015, ALFI responded to the EBA consultation on draft guidelines on sound remuneration policies under Article 74(3) and 75(2) of Directive 2013/36/EU and disclosures under Article 450 of Regulation (EU) No 575/2013.
On 29 May 2015, ALFI responded to the second FSB and IOSCO consultation on “Assessment methodologies for identifying non-bank non-insurer global systemically important financial institutions (NBNI G-SIFIs)”.
ALFI response to the European Commission consultation regarding an EU framework for simple, transparent and standardised securitisation- ALFI statements
On 18 February 2015, the EU Commission presented a consultation on an EU framework for simple, transparent and standardised securitisation. The wish to create a sustainable market for high-quality securitisation which is part of the Commission’s Investment Plan for Europe announced on 26 November 2014 was identified as one of the five areas where short-term action was needed.
On 18 February 2015 the European Commission presented its Green Paper on building a Capital Markets Union (“CMU”). The CMU project was announced in July 2014 by EU Commission President Juncker as part of his five-year agenda and a key part of the EU Commission’s 10 priorities. In its political ambition, it seeks to remove barriers to the free flow of capital in Europe, and increase the role that market-based finance plays in intermediating capital to European companies, projects and governments.
On 27 March 2015 ALFI submitted its response to the ESMA Discussion Paper on share classes of UCITS. Issues addressed in this paper relate to the definition of a share class, the different types of existing share classes in the various Member States of the EU and the possible approaches to developing a common understanding on the share classes that should be permitted.
On 23 February 2015, ALFI responded to the consultation on cross-border regulation which was published in November 2014 by IOSCO.
On 17 February 2015, ALFI responded to the discussion paper on key information documents (KIDs) for packaged retail and insurance-based investment products (PRIIPs), which was published in November 2014 by the European Supervisory Authorities (ESAs).
ALFI response to ESMA consultation paper on the review of the technical standards on reporting under Article 9 of EMIR- ALFI statements
On 10 February 2015, ALFI responded to ESMA consultation paper on the review of the technical standards on reporting under Article 9 of EMIR.