Over the year, ALFI participates in numerous consultations issued by European Institutions and industry associations.
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.
ALFI’s response to CESR’s consultation on its guidelines for the transition from the simplified prospectus to the key investor information document (Ref. CESR/10-672)- ALFI statements
According to the UCITS IV Directive (2009/65/EC), Member States can decide whether or not to allow UCITS established in that State up to 12 months to implement the Key Investor Information. In trying to balance the scope for consumer confusion with the costs to be borne by management companies and ultimately consumers, CESR’s guidelines set out what it considers to be the appropriate approach that management companies should take during the transitional period. The guidelines will enter into force in line with the transposition deadline for the revised UCITS Directive (1 July 2011).
ALFI wholly supports CESR’s proposals for transition.
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ALFI’s response to CESR’s consultation on its level 3 guidelines on the selection and presentation of performance scenarios in the Key Investor Information document (KII) for structured UCITS (Ref. CESR/10-530)- ALFI statements
In terms of Key Investor Information, the UCITS IV Directive (2009/65/EC) requires for structured UCITS (including capital-protected and guaranteed UCITS) and other comparable UCITS the use of prospective scenarios, as presentation of past performance is not relevant. In order to ensure comparability between structured UCITS, the consistency in the choice of prospective scenarios and the format of the presentation of those scenarios, CESR has developed guidelines with a view to harmonising the selection and presentation of scenarios. Please click here.
ALFI’s response to CESR’s consultation on the guide to clear language and layout for the key investor information document (KII) (Ref. CESR/10-532)- ALFI statements
The Simplified Prospectus failed as a consumer communication because the rules led to long documents. In addition, many are written in technical or legalistic language and poorly structured and designed. The Key Investor Information document is a radical attempt to address these shortcomings. Although CESR does not believe there is a single right way to write and design a KID, its guide is intended to help to craft a KID by giving pointers to widely-accepted good practice.
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