Over the year, ALFI participates in numerous consultations issued by European Institutions and industry associations.
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
On 29 March 2018, ALFI responded to the survey for the European Commission on the Alternative Investment Fund Managers Directive (AIFMD).
On 14 March 2018, ALFI responded to the European Commission consultation on fitness check on supervisory reporting.
ALFI response to ESMA draft RTS on Securitisation Regulation on “Disclosure and Operational Standards”- ALFI statements
ALFI took the opportunity to provide high level comments on the second set of advice on specific items in the Solvency II Delegated Regulation, focusing in particular on the risk margin and its impact on the insurance world and thereby the impact on the asset management world.