Over the year, ALFI participates in numerous consultations issued by European Institutions and industry associations.
Call for evidence - transparency and distribution requirements for substitute retail investment products- ALFI statements
ALFI responded to the European Commission’s call for evidence on the need for a coherent approach to product transparency and distribution requirements for “substitute” retail investment products. The Association’s standpoint is to provide the Commission with an overview of product types which do not fall under the investment funds banner but may be considered as a source of unfair competition in relation to UCITS. Practical examples of missellings to investors in this context are also given, and the question of the advantages and disadvantages of UCITS and nationally regulated funds versus substitute retail investment products is also addressed in this paper. Finally ALFI makes recommendations as to the product disclosure in relation with MiFID rules and the Prospectus Directive’s provisions.
ALFI's response to CESR consultation paper regarding content and form of Key Investor Information disclosures for UCITS- ALFI statements
ALFI represents the Luxembourg investment management and fund industry. It counts amongst its membership asset management groups from various horizons and a large variety of service providers.
ALFI 1 welcomes the Commission’s initiative on a Call for Evidence regarding private placement
regimes in the EU.
ALFI supports measures aiming at facilitating cross-border private placements of investment funds
and of investment fund - like investment structures.
ALFI is of the view that the current absence of an EU – wide cross-border placement regime is an
obstacle to certain forms of capital raising and of capital spending notably in strategic segments of
the capital markets and amounts to a single market failure.
ALFI response to the European Commission’s "Exposure Draft" on initial orientations for discussion on possible adjustments to the UCITS Directive- ALFI statements
The Association of the Luxembourg Fund industry (ALFI) is the representative body of the Luxembourg fund industry. Its membership includes funds as legal entities and professionals of the fund sector, among which depositary banks, fund administrations, transfer agents as well as asset managers. ALFI welcomes the opportunity to comment on the above-mentioned consultation paper and wishes to congratulate the European Commission for the considerable efforts it has made to address the key issues facing the investment fund industry. ALFI is of the opinion that the Exposure
We are grateful that CESR has improved the proposals in a number of ways.
That the focus on fund commission has been replaced by a more balanced consideration of remuneration structures generally for instruments covered by MiFID is very welcome. However we note that where other instruments other than mutual funds use noncommission remuneration models they can be complex to unravel. This is true of a number of complicated financial instruments, such as certificates.
Position Paper on CESR’s public consultation concerning best execution under MiFID (Ref: CESR/07-050b)- ALFI statements
ALFI welcomes CESR’s analysis on “Best execution under MiFID” published in its public consultation of February 2007. Having a common approach between regulators on this topic will be most helpful for market participants.
We are supportive of the positions taken by CESR in this consultation, but recognise that there is still a need, not addressed in this paper, for guidance on best execution in the context of quote-driven markets (where we understand CESR is in communication with the EU Commission).
ALFI welcomes CESR’s analysis on “Inducements and MiFID” published in its public consultation of December 2006. The document identifies many key issues from the point of view of the Luxembourg fund industry. As MiFID will impact the fund distribution chain, ALFI welcomes the opportunity to participate in this consultation process by
commenting on this analysis and by explaining its position regarding the issue of inducements under the Directive.
ALFI is the representative body of the 1.8 trillion Euro Luxembourg fund industry. It counts among its memb
ALFI would like to congratulate the Expert Group for the excellent report (the “Report”) it produced on Investment Fund Market Efficiency. ALFI also salutes the European Commission for having set up the Expert Group and facilitated its discussions. The document identifies the most important expectations of the industry and its opinion on how to achieve an integrated single market for investment funds. ALFI welcomes the opportunity to comment on this important paper and urges the Commission to act on those areas where there is an agreement from the industry
ALFI salutes the European Commission for the position paper (the “Green Paper”) entitled “The Enhancement of the Regulatory Environment for Investment Funds”. The document identifies key issues to achieve a single market for asset management. ALFI welcomes the opportunity to comment on this important position paper.
ALFI is the representative body of the 1.4 trillion euro Luxembourg fund industry. It counts among its membership asset managers from various horizons and a large variety of service providers. As one of