Position papers, statements and consultation responses

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Response to ESMA Consultation on Sustainability in AIFMD/UCITS

19 February 2019, Invest Europe-PAE

In this response, we stress the need for ESMA to stick to a high-level principles-based approach, recognising the diversity among market practitioners and allowing a certain level of flexibility in implementation (according to the proportionality principle). In addition, it is important to avoid treating ESG as a standalone or overriding risk category in the deal process, but rather to consider it as a category of direct business risks, which should be incorporated in existing functions and processes.

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Response to ESMA Consultation on Sustainability in MiFID II

19 February 2019, Invest Europe-PAE

In this response, we express our support for ESMA’s proposed high-level principles-based approach, avoiding overly prescriptive rules, which could increase the risk of regulatory arbitrage. We also support ESMA’s recognition that any changes introduced should be applied by firms with the proportionality principle in mind, taking into account the size, nature, scale and complexity of their activities.

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Response to IOSCO Report on Leverage

1 February 2019, AIC/PAE

In this joint AIC/Invest Europe response, the private equity industry welcomes the two-step approach taken by IOSCO in determining consistent measures of leverage globally and advises the international regulator to explicitely exclude fund's exposures backed by uncalled commitments from the leverage calculation. 

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Position Paper on the Insolvency Directive

7 December 2018, Invest Europe-PAE

In this paper, the PAE welcomes the opening of interinstitutional negotiations on the insolvency file and puts forward several suggestions including on the cross-class cram down, voting procedure for approval of restructuring plans, debt-discharge period for entrepreneurs and the stay on enforcement of actions. 

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Response to EC Consultation on draft Solvency II Delegated Acts

6 December 2018, Invest Europe-PAE

In this response we stress the industry's support to the creation of a new category of long term equity exposures subject to a lower risk-weight, while explaining why the criteria proposed by the Commission to determine which investments fall into this category are inappropriate from our perspective. 

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Response to ESAs Consultation on KID_PRIIPs

6 December 2018, Invest Europe-PAE

In this response the PAE details the industry's concerns regarding the scope of the Key Information Document Regulation and the need to adapt it to sophisticated investors. It also highlights the irrelevance of existing performance scenarios for closed-ended and illiquid funds. 

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Response to EBA Guidelines on CRD/CRR high-risk exposures

16 July 2018, PAE-Invest Europe

In this response we outline several concerns regarding the EBA suggested approach to define the concepts of “investments in private equity” or “investments in venture capital firms” in the context of Article 128 of the Capital Requirements Regulation, as the proposed definitions could create more confusion than clarity, disicentivise banks' investment into private equity and venture capital funds and create a negative precedent for the industry in other legislation.

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Response to EFRAG Consultation on Equity Instruments – Impairment and Recycling

1 June 2018, PAE-Invest Europe

This consultation response explains that problems may arise as under the new standard, unrealised gains/losses would be immediately reflected in the Profit and Loss Statement (P&L). We propose flexibility to allow recycling for investors, i.e. to recognize unrealized gains and losses in Other Comprehensive Income and then recycle to the P&L, or if it wished to recognize unrealized gains and losses in the P&L straight away, then this would avoid unrealised gains/losses being immediately reflected in the P&L while not enabling the investor to use recycling as an earnings management tool.

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Position paper on the prudential treatment of investment firms

14 May 2018, Invest Europe-PAE

This position paper raises the concerns of private equity firms holding MiFID license regarding the new prudential regime proposed by the European Commission. It suggests that the new regime will lead to a significant increase in capital requirements for these investment firms, which is not proportionate to the risk they pose.

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Position Paper on the cross-border distribution of funds legislation

7 May 2018, Invest Europe-PAE

In this position paper, we welcome the European Commission's targeted amendments to AIFMD, ELTIF and EuVECA to reduce regulatory barriers to the cross-border distribution of investment funds in the EU but stress that the proposed Directive and Regulation are insufficiently tailored to the private equity and venture capital asset class, in particular regarding the definition of pre-marketing.

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