In our response to the survey we identify the current challenges and possible solutions to foster innovation. These solutions, which cover 4 different areas, include the identification and removal of regulatory burdens, the creation of a critical mass for VC in Europe through public support and the creation of the right conditions to strengthen patient capital in Europe, amongst others. We believe the implementation of these actions at pan-European level would contribute to strengthen the European innovation ecosystem for the ultimate benefit of European citizens and economy.
In this response, we explain a typical PE structure and the commercial purpose of each of the entities, and why these entities should not fall under the definition of shell entities. We believe that the commercial purpose of an entity is a good indicator for determining whether it is a shell entity or not, and must thus be taken into account in the definition.
This position paper describes the relationship between private equity and retail clients - suggesting key policy changes that could be introduced to make sure large sophisticated investors and small private ones are able to access the asset class directly or indirectly depending on their risk characteristics.
In this response we argue that changes should be made to the definition of a "professional investor upon request" to better acknowledge the features of long-term & sophisticated investors in asset classes such as private equity. We also describe to the European Commission our concerns with the current retail disclosure documents, which are too standardised to give investors an appropriate idea of the real risk and benefits of long-term investments.
This long awaited official Guidance from the European Commission clarifies the application of the Sustainable Finance Disclosure Regulation (SFDR). From our industry’s perspective, the letter clarifies that SFDR does apply to all AIFMs carrying out activities in the EU (including those gaining access through NPPRs), and clarifies the definitions of Article 8 and 9 products.
In this response, we comment on changes that have been introduced by the European Commission as well as present our own suggestions for Guidelines to fully play their role in allowing Member States to deliver aid to innovative and growing companies by providing targeted support to the private venture and growth funds that invest in them.
Ahead of the forthcoming AIFMD review, Invest Europe joined forces with other trade associations, such as AIMA, ACC and Inrev, to express our concerns to the European Commission on any changes policymakers are considering making to the AIFMD delegation regime. The letter explains, among others, how the EU benefits from the global nature of the fund management industry and that the EU fund management regulatory framework is robust and fit for purpose.
In our response, we welcome the Commission’s proposal for a CSRD and support the view that in order to achieve sustainable and inclusive growth it is key to have relevant, comparable and reliable sustainability information. That said, we ask the Commission to pay particular attention to certain aspects of the CSRD of key importance to the industry, such as the need for alignment, coherence and consistency on content and timeline with other pieces of legislation, such as the SFDR and the Taxonomy, and the importance of applying the materiality and proportionality principles when considering the extension of the scope to SMEs.
In this response, we shared our views on the European Commission’s initiative to mitigate a potential debt-equity bias induced by taxation. We notably stressed that the differences between the tax deductions of costs related to debt vs. equity should be dealt with in a way that allows for more deductions – not fewer. Thus, we are happy to support the idea of introducing an equity allowance.
This Q&A addresses the treatment of an institution’s investments into EU AIF managed by a non-EU AIFM and into closed-ended CIUs, flagging that clarification should be brought to such treatment to ensure that exposures to closed-ended funds are not given a risk weight that is not appropriate to the risk it poses.
Public Affairs Director
Senior Public Affairs Manager
Public Affairs Officer
Sofia Garrido Perez
Public Affairs Officer
Public Affairs Manager
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