The year 2021/2022 has been important in legislative terms for the asset management/investment fund industry. In July, the EU Commission presented its AML package including four legislative proposals, and in November it followed with its proposals reviewing the AIFMD and the ELTIF frameworks.
The review of the AIFMD has been well announced, and ALFI has been in a constant and fruitful dialogue with the EU Commission, Member States and MEPs over the whole 2021-2022 period. These exchanges took place before the Commission proposal and have been ongoing ever since. It also organised a public virtual debate featuring the rapporteur on the side of the European Parliament, the Presidency of the Council as well as the Commission. Over 800 participants registered for the event, including many decision-makers in Brussels.
As for the AIFMD, ALFI engaged with the Commission in the year running up to the publication of the proposal and since then with Member States, MEPs and other stakeholders. Here also the association organised a well-attended public virtual debate with speakers from the EU Parliament, the Council Presidency and the Commission.
The package shifts all requirements regarding obliged entities into a regulation and creates an AML authority at EU level. ALFI has been engaging with Member States, MEPs and other stakeholders over the past months focusing mostly on the two proposals mentioned above for a regulation.
ALFI has been engaging with EU stakeholders pushing for a prolongation of the exemption for UCITS to provide the PRIIPs KID until the PRIIPs level 2 enters into force. Furthermore, ALFI also mobilised efforts in order to give members the possibility to produce a PRIIPs KIID instead of a UCITS KID for professional investors. This will avoid the production of two KIDs.
Over the past 12 months ALFI has also engaged with the EU institutions on the upcoming review of the MMF regulation, on the “Unshell” directive, the retail investment strategy, securitisation and of course on sustainable and on digital finance.
The ALFI EU Representative Office in Brussels regularly reports internally on all relevant Council and European Parliament meetings and produces a daily monitoring report of news from the EU and international institutions, authorities and organisations as well as other stakeholders.
ALFI has been declaring its lobbying interests and resources via the European Transparency Register since its inception in 2008. The Association is also committed to the European Code of Conduct in the matter.
Antoine Kremer, Head of EU Rep Office