In this consultation response, Invest Europe has shared the industry's views on the European Commission's Renewed Sustainable Finance Strategy. Particular areas of focus were fiduciary duties, remuneration, financial stability risk, short-termism and due diligence.
In this consultation response, Invest Europe welcomes the high-level, principles-based approach adopted by the European Commission. It provides a level of proportionality and flexibility, which is key to enable financial market participants to implement the new requirements in a way that is in line with their business needs and supports the needs of their individual portfolio companies.
In this consultation response, Invest Europe welcomes the Commission’s high-level, principles-based approach to integrate sustainability into the AIFMD Delegated Acts. In light of the diversity among market practitioners, it is crucial to avoid a one-size-fits-all approach and to strive for appropriate rules that are practical, workable and proportionate, as such avoiding imposing unnecessary, additional burden on AIFMs.
In this consultation response, Invest Europe has expressed its support for the proposed amendments but has raised some concerns with the way MiFID has been implemented in certain countries, in particular in relation to what has been considered as “marketing”.
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 position paper, we stress the importance of the Capital Markets Union project and call 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.
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.
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