Over the year, ALFI participates in numerous consultations issued by European Institutions and industry associations.
Au nom de l’ALFI, son conseil d’administration, ses membres ainsi que ses employés, nous présentons à leurs Altesses Royales le Grand-Duc Henri et la Grande-Duchesse Maria Teresa, ainsi qu’à l’ensemble de la famille grand-ducale, nos plus sincères et respectueuses condoléances.
ALFI responds to the ESMA Consultation Paper on Guidelines on liquidity stress testing in UCITS and AIFs- ALFI statements
On the 1st of April 2019, ALFI responded to the ESMA Consultation Paper on Guidelines on liquidity stress testing in UCITS and AIFs.
ESMA has produced a set of fourteen (principles-based) draft guidelines for managers to fulfil when executing liquidity stress tests (LST) on their funds. Broadly, these guidelines set out that LST should: be tailored towards the individual fund, reflect the most applicable risks to a fund, be sufficiently extreme or unfavourable (yet plausible), sufficiently model how a manager is likely to act in times of stressed market conditions, and be embedded into the fund’s risk management framework. One guideline applies to depositaries, outlining how they should fulfil their obligations regarding LST. The guidelines were reinforced via a number of sections providing explanatory considerations for managers, to assist their compliance with the Guidelines.
Read ALFI’s response to the 32 questions.
ALFI's answer to the European Commission consultation on the update of the non-binding guidelines on non-financial reporting- ALFI statements
On 20 March 2019, ALFI answered to the European Commission consultation on the update of the non-binding guidelines on non-financial reporting.
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.
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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.