On 24 October 2016, ALFI responded to the EU Commission consultation “Review of the EU macro-prudential framework”.
ALFI limited its response to the following question: “Would you consider it appropriate to expand the macro-prudential framework beyond banking?”. ALFI pointed out that asset management and fund related activities do not entail structural vulnerabilities and that the sector is already highly regulated by regulations such as the UCITS Directive, AIFMD, Solvency II, MiFID, EMIR or the Securities Financing Transactions Regulation, dealing with both transparency of information and supervision of the asset management industry. Moreover, ALFI stated that investment funds contain characteristics that differentiate them from banks. Therefore, ALFI believed there should be little distress to the wider financial system in the event of the default of an individual asset manager given the high degree of competition and substitutability within this sector. Overall, ALFI was of the view that it is inappropriate to expand the macro-prudential framework beyond banking to asset managers and investment funds.