Over the year, ALFI participates in numerous consultations issued by European Institutions and industry associations.
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.
Position Paper on the CSSF Regulation N° 10-4: Treatment of subscription and redemption orders under UCITS IV- ALFI statements
The main objectives of this ALFI Position Paper is to outline ALFI’s recommendations by way of providing Best Market Practice Guidelines on the treatment of subscription and redemption orders. This document contains the ALFI UCITS IV Operations Working Group’s (serving under the ALFI TA & Distribution Forum) assessment of the current market practice across a representation of Luxembourg fund industry participants from the perspective of global cross-border fund servicing of Luxembourg-domiciled funds.
ALFI comments to the International Accounting Standards Board (IASB) Exposure Draft ED/2011/4 « Investment Entities ».- ALFI statements
On 5 January 2012, ALFI submitted its comment letter to the IASB Exposure Draft ED/2011/4 .
On October 25, 2011, EIOPA invited market participants and occupational pensions stakeholders to participate in the second consultation on the revision of the IORP directive. EIOPA requested input on all 23 areas of the Call for Advice, including the nine areas that were addressed in the first consultation in July/August 2011. To read ALFI’s response please click here.