Position papers, statements and consultation responses

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Response to Commission consultation on institutional investors and asset managers' duties regarding sustainability

22 January 2018, Invest Europe-PAE

In this response, Invest Europe has confirmed its support for the European Commission’s work in this field, recognising the fiduciary duty of institutional investors and asset managers to incorporate sustainability factors in their investment decisions and monitoring. However, we feel it is important to maintain a certain level of discretion and flexibility, as it will be up to asset managers and investors themselves to decide and agree on how they do this given they might have different (responsible) investment approaches, clients and beneficiaries, and operate under different (national) legislation.

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Response to Commission Consultation on SME listing

15 January 2018, Invest Europe-PAE

In this response, the private equity industry supports the European Commission’s initiative to reduce the burden of public offering for smaller firms, noting that these firms are often discouraged from seeking to launch an Initial Public Offering (IPO) on public markets given the amount of requirements they are subject to. 

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Response to EIOPA second set of advice on Solvency II risk weights

5 January 2018, Invest Europe-PAE

The consultation launched in November 2017 is EIOPA’s final step to reassess the treatment of unlisted equity in the context of Solvency II review. This response reiterates our concern that the current 39% risk charge for private equity does not reflect the actual risk insurers face when investing in the asset class. It suggests therefore that a sub-category of asset should be created to allow for a more appropriate risk calibration. It also underlines that in setting a sound regulatory framework for risk calibration, it is critical that the approach taken reflects the way in which exposure to private equity is achieved by insurers.

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Position Paper on the ESAs Review

19 December 2017, Invest-Europe-PAE

This position paper welcomes the publication of the Commission proposal reviewing the European Supervisory Authorities (ESAs). More specifically, it comments on the new ESMA direct supervisory powers over EuVECA and ELTIF funds, on the new funding and governance model and on the risks of making outsourcing and delegation arrangements more difficult.

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Response to Commission Consultation on Fiduciary Duties

11 December 2017, Invest Europe-PAE

In this response, Invest Europe has expressed its support for the European Commission’s work in this field, recognising that ESG factors should be part of the fiduciary duty of institutional investors and asset managers. However, there are a few issues that ought to be considered: (i) “material sustainability” should be properly defined; (ii) a one-size-fits-all solution would not be appropriate; and (iii) careful thought should be given to the right way forward (legislative or non-legislative).

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Response to HLEG consultation on its interim report on Sustainable Finance

20 September 2017, Invest Europe-PAE

In this response Invest Europe has expressed its support for the work of the High Level Expert Group, highlighting the important role that private equity can play in the achievement of the EU’s goals on sustainable finance and development. In addition, we emphasised the need to take account of existing international classification systems, labels and standards and expressed our concerns about the implications this work-stream may have on certain parts of financial services legislation.

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Response to Commission Consultation on "Reducing barriers to cross-border distribution of investment funds”

14 July 2017, Invest Europe-PAE

In this response Invest Europe welcomes the Commission’s potential initiative to reduce national regulatory barriers to the cross-border distribution of investment funds and agrees with the identified policy areas, such as the definition of marketing or regulatory fees currently imposed on fund managers.

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Response to Commission Consultation on the review of the SME definition

6 July 2017, Invest Europe-PAE

This response to this Commission Inception Impact Assessment welcomes the Commission consideration to revise the SME definition and suggests this revision should make clear that firms backed by private equity and venture capital investors do not, solely by virtue of that ownership form, fall outside the definition of an SME.

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AIFMD Essentials 2017

24 May 2017, Invest Europe

This member guide to the AIFMD, explains its key provisions and implementing measures from a private equity perspective. It sets out the requirements for GPs and covers the impact on investors and fund-of-funds.

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Response to EIOPA Call for Evidence on Solvency II treatment of unlisted equity and debt

24 May 2017, Invest Europe-PAE

This response summarises the private equity industry’s position on the criteria that could be used to identify unlisted equity to which a lower risk charge could be applied. It also reiterates our concerns that existing Solvency II capital charges does not reflect the actual risk insurers face when investing in the asset class and argues that it should be significantly lower than the existing 39%. The Call for Evidence is part of the technical work undertaken by EIOPA to advise the European Commission on the reassessment of the risk-weighting for insurers' investments into unlisted equity and debt as part of their Solvency II review in 2018. 

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