Over the year, ALFI participates in numerous consultations issued by European Institutions and industry associations.
ALFI’s response to ESMA’s consultation on the draft regulatory technical standards under the ELTIF Regulation- ALFI statements
According to the ELTIF Regulation, ESMA shall develop draft regulatory technical standards (RTS) to determine the criteria for establishing the circumstances in which the use of financial derivative instruments solely serves hedging purposes, the circumstances in which the life of a European long-term investment fund is considered sufficient in length, the criteria to be used for certain elements of the itemised schedule for the orderly disposal of the ELTIF assets, the costs disclosure and the facilities available to retail investors. This consultation paper represents the first stage in the development of the draft RTS.
ALFI response to IOSCO consultation report on Elements of International Regulatory Standards on Fees and Expenses of Investment Funds- ALFI statements
On 23 September 2015, ALFI responded to the International Organization of Securities Commissions (IOSCO) consultation report on Elements of International Regulatory Standards on Fees and Expenses of Investment Funds, which proposes an updated set of common international standards of best practice for the operators of Collective Investment Schemes(CIS) and regulators.
On 17 August 2015, ALFI responded to the technical discussion paper on packaged retail and insurance-based investment products (PRIIPs), which was published end of June 2015 by the European Supervisory Authorities (ESAs).
ALFI response to the EC consultation on regulation EU No 648/2012 on OTC derivatives, central counterparties and trade repositories- ALFI statements
ALFI responded to the EC consultation on regulation EU No 648/2012 on OTC derivatives, central counterparties and trade repositories.
ALFI responds to the OECD Public Revised Discussion Draft “BEPS Action 6: Preventing Treaty Abuse” dated 22 May 2015- ALFI statements
ALFI responded to the OECD Public Revised Discussion Draft “BEPS Action 6: Preventing Treaty Abuse” dated 22 May 2015.
On 27 March 2015, the Luxembourg draft law on FATCA was submitted to Parliament. The law will ratify the execution of the Intergovernmental Agreement (IGA) signed between Luxembourg and the United States of America on 28 March 2014 as well as the related Appendices and Memorandum of Understanding. It is expected that the law will be passed in the coming days. In this context, ALFI's implementation working groups for FATCA prepared a Q&A document to deal specifically with reporting and withholding issues in the context of FATCA.
ALFI response to EBA consultation paper on draft EBA guidelines on limits on exposures to shadow banking entities- ALFI statements
On 19 June 2015 ALFI responded to the EBA consultation paper on draft guidelines on limits on exposures to shadow banking entities. The EBA proposes, in the absence of a definition of “shadow banking entities”, to include alternative investment funds and money market funds under the definition of shadow banking entities which carry out banking activites outside a regulated framework. To read the full response please click here.
On 4 June 2015, ALFI responded to the EBA consultation on draft guidelines on sound remuneration policies under Article 74(3) and 75(2) of Directive 2013/36/EU and disclosures under Article 450 of Regulation (EU) No 575/2013.
On 29 May 2015, ALFI responded to the second FSB and IOSCO consultation on “Assessment methodologies for identifying non-bank non-insurer global systemically important financial institutions (NBNI G-SIFIs)”.
ALFI response to the European Commission consultation regarding an EU framework for simple, transparent and standardised securitisation- ALFI statements
On 18 February 2015, the EU Commission presented a consultation on an EU framework for simple, transparent and standardised securitisation. The wish to create a sustainable market for high-quality securitisation which is part of the Commission’s Investment Plan for Europe announced on 26 November 2014 was identified as one of the five areas where short-term action was needed.