Over the year, ALFI participates in numerous consultations issued by European Institutions and industry associations.
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.
ALFI's response to consultation on institutional investors and asset managers' duties regarding sustainability- ALFI statements
On 22 January 2018, ALFI submitted its response to the European Commission consultation on institutional investors and asset managers' duties regarding sustainability.
On 15 January 2018, ALFI submitted its comments about the draft guidelines issued by ESMA in November last year regarding positions to be produced by Trade Repositories in accordance with EMIR.
On 3 January 2018, ALFI responded to the public consultation on Fair Taxation of the Digital Economy issued by the European Commission in October last year.
alfi Responds to European Commission inception impact assessment on institutional investors’ and asset manager’s duties regarding sustainability- ALFI statements
For the purpose of the present position paper, sustainability factors relate to environmental, social and governance issues as defined in the glossary of the public consultation.