Over the year, ALFI participates in numerous consultations issued by European Institutions and industry associations.
The recent update of the SIF Law includes the requirement, in accordance to article 42bis, for each Specialised Investment Fund (“SIF”) to have appropriate risk management systems in place to identify, measure, manage and monitor the risks associated with the positions and their contribution to the overall risk profile of the portfolio.
ALFI Comments in the IOSCO Consultation Report on Suitability Requirements for the Distribution of Complex Financial Products- ALFI statements
On 18 May 2012 ALFI responded to IOSCO’s ConsultationReport on Suitability Requirements with respect to the Distribution of Complex Financial Products. Topics covered in this paper are among others the classification of retail and non-retail investors, disclosure methods, investor protection means in case of sale of complex products on an unsolicited basis, and information on the basis of the advice provided by the intermediary.
ALFI Comments to the IOSCO Consultation Principles for the Valuation of Collective Investment Schemes- ALFI statements
On 18 May ALFI commented on the IOSCO Consultation Principles for the Valuation of Collective Investment Schemes.The consultation report sets out principles which can be utilised in order to assess the quality of regulation and industry practices regarding the valuation of CIS with a view to ensuring the fair treatment of investors. It updates and modernises IOSCO’s Principles for CIS Valuation (which was originally developed in 1999) so as to take into consideration subsequent regulatory, industry and market developments. It also clarifies some concepts put forward by IOSCO in its report “Principles for the Valuation of Hedge Fund Portfolios”, such as the entity responsible for establishing a policy governing valuation and the independence of the valuation duty.
ALFI comments on the ESMA / EBA / EIOPA Discussion Paper on Draft Regulatory Technical Standards on risk mitigation techniques for OTC derivatives not cleared by a CCP under the Regulation on OTC Derivatives, CCPs and Trade Repositories- ALFI statements
ALFI welcomes the ESMA / EBA / EIOPA discussion paper – Draft Regulatory Technical Standards on risk mitigation techniques for OTC derivatives not cleared by a CCP under the Regulation on OTC derivatives, CCPs and Trade Repositories.
Regarding these Draft Regulatory Technical Standards, the ALFI EMIR and OTC Derivatives Working Group has analyzed the document and has the following comments.
The Working Group decided not to answer to all the questions raised in this document however to transmit a few general elements or remarks.
ALFI’s response to the Consultation concerning ESMA guidelines on ETFs and other UCITS issues (ESMA/2012/44)- ALFI statements
On 30 March ALFI responded to Consultation concerning ESMA guidelines on ETFs and other UCITS issues.
ALFI’s response to ESMA discussion paper « Key concepts of the Alternative Investment Fund Managers Directive and types of AIFM- ALFI statements
On 23 March ALFI responded to ESMA discussion paper on Key concepts of the AIFMD and types of AIFM.
ALFI welcomes the ESMA discussion paper – Draft Technical Standards for the Regulation on OTC Derivatives, CCPs and Trade Repositories as very positive and fully supports the initiatives aimed at enhancing safety and transparency in the over-the-counter derivatives market.
Regarding these Draft Technical Standards, the ALFI EMIR and OTC Derivatives working Group has analyzed the document and has some more specific comments. The Group decided not to answer to all the questions raised in this document however, only to a selection of questions that are developed in the ALFI position paper and that appear to be more relevant for the fund’s industry.
On 24 February 2012 ALFI responded to ESMA’s consultation paper on the guidelines on certain aspects of the MiFID Compliance function requirements.
On 24 February 2012 ALFI responded to ESMA’s consultation paper on the guidelines on certain aspects of the MiFID suitability requirements.
In January 2012, ALFI responded to the questionnaire on MiFID/MiFIR 2 by Markus Ferber MEP.