Guidelines on sound variable remuneration will apply to all MiFID investment firms, although some rules will be waived below a defined threshold. In this response we reiterate the importance of protecting the carried interest model while flagging some technical concerns we have with some sections of the Guidelines, including on the definition of the thresholds.
Maaike van der Schoot (AlpInvest Partners), Erwann Le Ligné (Eurazeo), Patrick Sheehan and Rob Genieser (ETF Partners), and Cilia Holmes Indahl (EQT) joined our launch webinar on 15 March to shed more light on the new Invest Europe Climate Change Guide. The recording of the webinar is available in the Members' Policy Call section of the website.
As investors in innovative and high-growth companies and start-ups we believe it was necessary to position ourselves on the issue. We support and welcome the EC’s ambitions and 2030 digital targets, and we want to make sure that the PE/VC industry is seen as key enabler of the digital transformation. Moreover, we want to ensure that the EC makes creating the right policy and tax environment to allow the digital transformation one of its priorities as these will be essential in achieving the 2030 digital targets.
In our response we highlight the need for the collection of financial and environmental data in a harmonised way whilst ensuring that this is of the highest quality and foremost reliable. Moreover, we also point out the need of correctly assessing the costs for data providers. We believe is necessary to ensure that no further administrative burden or duplication of information requirements arise as a result of the establishment of the ESAP.
In this letter, Invest Europe expresses its concerns about the draft RTS under SFDR that were published by the European Supervisory Authorities (ESAs) on 4 February. In particular, we shed light on issues of potential overreach by the ESAs and/or divergence from the Level 1 legislation.
Adinah Shackleton (Permira Advisers), Maaike van der Schoot (AlpInvest Partners) and Philip Bartram (Travers Smith) joined on 15 February a call to discuss the new SFDR rules in light of the forthcoming application date on 10 March 2021. In addition to the Known Unknowns, the call, whose recording is available on the Member Policy Calls' section of the website, also touched upon the recently published Regulatory Technical Standards (RTS) under SFDR.
In this response we have expressed our concerns that ESMA has not taken proper account of the differences between the overwhelmingly institutional AIF industry and the retail fund industry, with respect to their respective distribution models. Concretely, ESMA has made some assumptions about the application of MiFID rules in the institutional marketplace which are not necessarily correct. This is particularly relevant in the context of: (i) the categorisation of AIF marketing as a MiFID investment service or activity; and (ii) the disclosure of information on past and expected future performance.
In this consultation response, we have shared our views on the European Commission's Initiative on Sustainable Corporate Governance. Particular areas of focus were directors’ duty of care and due diligence duty. We stressed that while there are a number of good principles behind the idea put forward by the European Commission – such as holding directors accountable for creating real long-term value – it would create significant uncertainties and risks, if directors could be held to account by all different kinds of stakeholders, with no clear prioritisation on how they should weight all the different stakeholders’ interests.
Ahead of the fast approaching application date (10 March 2021), Invest Europe has been in contact with the European Commission to express its concerns about some of the grey areas around SFDR, including the scope of Article 8 and the public disclosures pursuant to Article 10 by private funds.
In this consultation response, Invest Europe reiterates that there is no need for a re-opening of the AIFMD because of a variety of factors. In addition, any changes to the AIFMD regime would lead to additional costs and (administrative) burden for the industry as members will need to re-adapt and get to grips with new requirements. If necessary, improvements to the AIFMD regime can be sought via Level 2 or 3 measures, or in the context of other legislative reviews.
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