In this consultation response, Invest Europe welcomes the envisaged increased transparency by national competent authorities on national marketing requirements for AIFs and the levying of regulatory fees and charges. That said, Invest Europe does call on ESMA to make sure that these new disclosure obligations do not lead to additional administrative and/or reporting requirements being imposed on fund managers.
In this response, we welcomed the findings contained in the report of the High Level Forum on the Capital Markets Union, stressing the need for the European Commission to make it easier for professional and sophisticated investors to commit capital into the asset class.
In the context of a potential extension of the Temporary Framework to start ups, we call EU policymakers to explicitly authorise state aid schemes to businesses backed by venture capital and private equity. We describe why these viable companies are currently at risk of being considered "in difficulty", and hence excluded from the rules, due to the existing skewed state aid definitions.
Invest Europe supported a joint industry letter on the consistent application of the DAC 6 deferral.
In this response we encourage the European Commission to be extremely cautious about expanding the scope of the NFRD too widely and too quickly, taking into account the disproportionate impact this could have on non-listed companies and in particular SMEs. Any changes to the NFRD regime should be considered in light of proportionality, materiality and flexibility. A voluntary and gradual approach is preferred.
As the Foreign Direct Investment (FDI) screening landscape across Europe is rapidly evolving, Invest Europe has prepared a country-by-country overview to map different existing regimes and keep-track of latest developments with view to helping members assess how FDI screenings may impact their transactions.
In this response we call the European Commission to introduce changes to its securities markets framework as part of its upcoming review, in particular when it comes to investor protection rules. Our main request is the reconsideration of the treatment of "sophisticated investors", such as HNWIs, which have so far been considered as retail clients under EU law.
In this letter we express our concerns with some of the disclosure requirements ESMA would like to require from third country investments firms in its technical standards on the provision of investment services and activities in the Union.
In this reply three EU Commissioners agree and comment on the priorities suggested by Invest Europe to help our industry and the companies it supports face the Covid-19 crisis.
In this letter, we stress that the "undertakings in difficulty" (UIDs) definition in the Global Block Exemption Regulation (GBER) is wrongfully categorizing as in difficulty performing private equity-backed businesses that may as a result get excluded for liquidity support granted to businesses in the context of the Covid-19 crisis.
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