This consultation response has been written from a pure AIFMD perspective, outlining in great detail the issues private equity fund managers are facing with the Directive’s requirements in the field of registration, notification and supervisory reporting. Special attention is paid to the divergent application and implementation of the Annex IV requirements.
This Europe Economics report commissioned by Invest Europe shows the impact that the Alternative Investment Fund Managers Directive (AIFMD) has had on private equity fund managers, their investors and the real economy since its entry into force in July 2013.
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.
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.
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.
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.
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).
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.
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.
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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