As the representative body of the Luxembourg investment fund community, ALFI shares its comments and concerns on manifold topics with the regulatory entities at national and international levels.

Within the year in review, ALFI has provided the following responses/comments[1]:

  • European Commission consultation on NFRD review
  • European Commission consultation on digital finance strategy for Europe
  • ESMA consultation on draft ITS under EU Regulation facilitating cross-border distribution of collective investment undertakings
  • EBA consultation on ML/TF risk factor Guidelines
  • Comments on the European Commission's draft delegated acts on the integration of sustainability factors under UCITS, AIFMD and MiFID
  • European Commission consultation on the renewed sustainable finance strategy
  • ESMA on outsourcing to cloud service providers
  • ESMA consultation Guidelines on art. 25 AIFMD
  • ESA consultation on ESG Disclosures
  • IOSCO Consultation Principles on Outsourcing
  • ESA survey on product disclosure templates under the SFDR
  • ESMA consultation on a draft advice to European Commission under Article 8 of the Taxonomy Regulation
  • OECD Reports on Pillar One and Pillar Two Blueprints
  • Comments on the European Commission roadmap on the review of VAT rules for financial and insurance services
  • Feedback to European Commission roadmap on AIFMD review
  • European Commission consultation on the ELTIF review
  • European Commission consultation on the review of the Alternative Investment Fund Managers Directive (AIFMD)
  • ESMA consultation on marketing communications
  • Feedback to European Commission on a recognition of US Prudential Regulators’ rules on over-the-counter (OTC) derivatives
  • European Commission targeted consultation on the establishment of a European single access point (ESAP) for financial and non-financial information publicly disclosed by companies
  • ESMA consultation on Fees charged to Credit Rating Agencies by ESMA
  • European Commission consultation on EU framework for markets in crypto-assets
  • European Commission public consultation on the review of VAT rules for financial and insurance services
  • European Commission consultation on the review of the Directive on settlement finality in payment and securities settlement systems (SFD)
  • European Commission consultation on the review of the Directive on financial collateral arrangements (FCD)
  • ESA Joint Consultation concerning taxonomy-related sustainability disclosures
  • European Commission consultation on supervisory convergence and the single rulebook

 

[1] ALFI responses can be found here: https://www.alfi.lu/en-gb/news/category/statementsandpositionpapers