Position papers, statements and consultation responses

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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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Response to European Supervisory Authorities Review Consultation

16 May 2017, Invest Europe-PAE

The PAE response to this Commission Consultation details the views of the private equity industry on potential changes made to the European Supervisory Authorities (ESAs) structure, governance and funding, in particular the suggestion for the ESAs (which include ESMA, EIOPA and EBA) to be funded directly by industry participants. 

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The Use of Holding Companies and Choice of Jurisdictions by the Private Equity Industry

4 May 2017, Invest Europe

With the OECD work on Base Erosion & Profit Shifting (BEPS) now nearing its completion, and with various new tax rules having being agreed at EU level to increase transparency, significant reform has been brought about in the tax domain. At Invest Europe, we have contributed to numerous consultations and proposals to ensure that any new rules do not have unintended consequences. This short note brings together our common messaging on tax issues concisely explaining why private equity funds use structures such as holding companies and invest via certain jurisdictions.

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Response to Commission Consultation on prudential treatment of investment firms

19 April 2017, Invest Europe

In this response to the Commission Inception Impact Assessment on its future proposal on the prudential treatment of investment firms, Invest Europe supports the principle of establishing a prudential regime better tailored to investment firms but details its concerns over a proposal that would not take into account the specificities of the private equity industry

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Response to Capital Markets Union Mid-Term Consultation

17 March 2017, Invest Europe- PAE

This consultation response details what additional actions Invest Europe would like the Commission to take to improve the state of European capital markets. The main focus is put on the improvement of the existing passporting framework (whether through the EuVECA review or limitations to existing fees and charges) and ways to allow an easier access to the asset class for institutional and sophisticated investors.  

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