Over the year, ALFI participates in numerous consultations issued by European Institutions and industry associations.
In April 2011, the European Commission asked EIOPA to provide advice on the legislative framework for Institutions for Occupational Retirement Provision (IORPs) by mid–December 2011. EIOPA invited market participants and occupational pensions stakeholders to provide comments by 15 August on the “Draft Response to Call for Advice”.
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Discussion Paper on ESMA's policy orientations on possible implementing measures under Article 3 of the Alternative Investment Fund Managers Directive – ALFI response- ALFI statements
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In February 2011, the Commission launched a public consultation in order to receive stakeholder feedback on its initiative for the taxation of the financial sector. The Commission wanted (i) to test its assumptions and collect related evidence as regards the definition of the problems, (ii) to assess the impacts of the set of policy options and (iii) to consult on more detailed aspects of the feasibility and design of the policy option.
ALFI responded in a specific paper to the European Commission’s consultation on the MiFID review. The paper addresses among other the questions related to the possible limitation of MiFID exemptions, the modification of the “execution only” regime and the Commission’s suggestion to impose additional obligations in the context of investment advice.
ALFI response to the European Commission consultation paper on legislative steps for the PRIP's initiative- ALFI statements
ALFI responded to the European Commission’s consultation paper on packaged retail investment products (“PRIPs”). ALFI strongly support the creation of a level playing field through a cross-sectoral approach to the regulation of retail investment products, focusing in particular on pre-contractual product disclosure. The rationale for the PRIPs initiative is a level playing field for investment products sold to retail investors in order to create a standard of investor protection. The UCITS framework embodied a high level of investor protection and the application of the UCITS disclosure standards to all PRIPs help retail investors to understand, compare and use product disclosure information in order to make informed investment
European Commission’s consultation on the UCITS depositary function and on the UCITS managers’ remuneration- ALFI statements
The ABBL/ALFI Depositary Bank Forum has submitted its response to the European Commission’s consultation on the UCITS depositary function and ALFI has also submitted its response on the UCITS managers’ remuneration.
ALFI has published a VAT update regarding the deduction right of investment funds and their service providers, and the VAT treatment of outsourcing of investment funds services. It aims to summarise recent discussion with the Luxembourg VAT administration. Please click here
Call for Evidence - Implementing measures on the Alternative Investment Fund Managers Directive – ALFI response- ALFI statements
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The Respondents share the analysis of the European Commission and its concerns regarding the adequacy of the current European pension systems, and encourages the European Commission to support the Members States in their efforts to strengthen adequacy. The Respondents call for more harmonization and consistency in the EU. If the adoption of the IORP Directive was indeed a major achievement, there are still barriers to cross-border activities.