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The document serves as BETTER FINANCE response to selected questions of ESMA’s discussion paper on the implications of digitalisation for investor protection under MiFID II. The document “Discussion Paper on MiFID II investor protection topics linked to digitalisation” provided by the European Securities and Markets Authority (ESMA) focuses on various aspects of digitalisation in the

We are pleased to share that Jesse Collin, from BETTER FINANCE member organization Finnish Share Promotion Foundation, has been selected as a member of ESMA’s Consultative Working Group in the Risk Standing Committee – Investor Trends and Research Working Group. The working group will focus on consumers, ESG and innovation related topics. For a full

BETTER FINANCE agrees with ESMA that names can be misleading if those funds do not invest in line with what their names would suggest.

Retail investors are increasingly concerned about the impact of their investment decisions on society and the environment. In recent years, European Union (EU) institutions have amended the legislation regarding the distribution of retail investment products by investment firms–the Markets in Financial Instruments Directive (MiFID II)–and related delegated legislation and guidelines to define how investment firms

ESMA’s Guidelines on funds’ names using ESG or sustainability-related terms in their names propose the use of quantitative thresholds whereby “if an investment fund has any ESG-, or impact-related words in its name, a minimum proportion of 80% of its investments should be used to meet the environmental or social characteristics or sustainable investment objectives…”

According to the European Securities and Markets Authority’s (ESMA) recent study on the EU Eco-label awarded to green retail financial products and services, only 16 funds out of a sample of 3000 meet the proposed minimum portfolio greenness threshold of 50% and exclusion requirements. In view of these findings, the supervisor has suggested loosening requirements

The European Commission published a legislative proposal for a regulation on European green bonds, which is supposed to become the high quality voluntary European Green Bond Standard. Its intention is to use the potential of the single market for achieving the EU’s climate and environmental goals in a more efficient way.

There is a growing wave of ESG regulation and an increasing need for ESG reporting – nationally, regionally and internationally. In Europe, ESG rating and data providers are indicative of an immature but growing market, which has seen the emergence of a small number of large non-EU headquartered providers.

The International Financial Reporting Standards (IFRS) created the International Sustainability Standards Board “to provide the global financial markets with high-quality disclosures on climate and other sustainability issues.” As part of its work, the ISSB published two exposure drafts on climate-related disclosures and geenral requirements for disclosure of sustainbility-related financial information.

ESMA, the European Securities and Markets Authority will issue further guidance in March to clear up confusion among exchange traded fund providers regarding upcoming UCITS rules on securities lending, according to the Financial Times. "Esma’s Ucits guidelines, which come into force on February 18, will require asset managers to return all securities lending revenues “net

EXECUTIVE SUMMARY Long-term investor engagement and sustainable corporate governance hampered by antiquated, fragmented and costly processes in the hands of financial intermediaries Despite the great importance the EU attaches to corporate governance (the ‘G’ part of ‘ESG’) and to shareholder engagement, there are still considerable obstacles to the exercise of shareholder voting rights; namely the

The EU taxonomy for sustainable activities (i.e. “green taxonomy”) is a classification system established to clarify which investments are environmentally sustainable, in the context of the European Green Deal. The aim of the taxonomy is to prevent greenwashing and to help investors make greener choices. The Taxonomy Regulation (complemented by the Sustainable Finance Disclosure Regulation)

BETTER FINANCE notes that the gap between users’ information needs and the sustainability information reported by undertakings is growing. Academic research demonstrates however that companies are reporting more often on aims and intentions rather than on actual actions and performance. Besides, there is a significant increase in demand for sustainability reporting information from undertakings which

BETTER FINANCE welcomes the Delegated act obligations for certain large undertakings to publish non-financial information. The rules set out in the delegated act clarify and allow for the translation of the technical screening criteria of the Climate Delegated Act (and the future Environmental Delegated Act) into quantitative economic performance indicators that will need to be

BETTER FINANCE welcomes the initiative of ESMA to clarify certain aspects related to the application of the MiFID II provisions on the appropriateness test and requirements for execution-only services. In addition, BETTER FINANCE commends ESMA on adapting the Guidelines on suitability assessment for the appropriateness test as the two procedures are, to a certain extent,

This document contains the response of BETTER FINANCE to the European Commission’s online survey (public consultation) concerning the consultation on the renewed sustainable finance strategy. BETTER FINANCE considers that the regulation on disclosures relating to sustainable investments and sustainability risks and amending Directive (EU) 2016/2341 is extremely important to clarify fiduciary duties and increase the

Summary: General comment The review of the MiFID II framework is timely and should be coordinated with the other ongoing actions and policy areas, i.e. PRIIPs and the work done in the Forum on the Future of the Capital Markets Union. In addition, to ensure a level playing field, the European Commission should also adopt

Closing Speech by Guillaume Prache at the Sustainable Value for Money Conference on 20 November 2019 — Download the PDF version here — BETTER FINANCE strongly supports the ambitions, the strong focus and considerable efforts of the EC with respect to sustainable finance. In particular: The so called “taxonomy” which we ask to be fact

CONSOB, the Italian financial watchdog, invited me on November 8, 2019 to comment on their very interesting 2019 report on the behavior of Italian savers. Several findings were indeed thought-provoking. For example, 63% of Italian savers are loss averse according to the Report. However, their top choice (and more and more so) is bank accounts.

EU authorities should prioritise the long overdue full PRIIPs Regulation review, and the UCITS funds’ exemption should be extended until this review is completed, as intended by EU Law. The organisations representing individual, non-professional investors and financial analysts advise the European Commission, the European Supervisory Authorities (ESAs) and the EU co-legislators against further delaying the

LUXEMBOURG, 4 NOVEMBER 2019  – Document optimisation company More Carrot has completed what is believed to be the industry’s first study of UCITS prospectuses. The findings shed light on a range of issues, including who uses prospectuses, the main purposes of use, what types of information they look for and how easy it is to

BETTER FINANCE welcomes the recent efforts of ESMA to clarify and harmonise across the EU the provisions and supervisory practices on the management and transparency of information concerning UCITS and AIF funds, and in particular the current proposal to codify uniform rules applicable to performance fees. As a representative of retail investors (among others), BETTER FINANCE

This research paper is part of BETTER FINANCE’s #FundResearch project, an umbrella research activity aimed at providing qualitative and quantitative assessments of the EU market for “retail” investment funds, focusing on Undertakings for Collective Investment in Transferable Securities (UCITS) and Alternative Investment Funds (AIFs). This paper looks into the practice of securities lending as an

When the European Securities and Markets Authority (ESMA) updated its Questions and Answers (Q&As) regarding the application of the Undertakings in Collective Investments in Transferable Securities (UCITS) Directive on 29 April 2019, BETTER FINANCE was happy to find that ESMA heeded our calls to better address various disclosure issues and closet indexing in general. The

The European Commission (EC) engaged in a project of overhauling the EU financial framework in line with the actions identified in the “Action Plan: Financing a Sustainable Growth”. The project consists of a package of measures (amendments to existing legislative and non-legislative acts; adoption of delegated acts) in order to increase transparency and disclosure of

The European Securities and Markets Authority (ESMA) initiated a peer review and published a report that found that six national competent authorities (NCAs) need to enhance their supervision of Undertakings for Collective Investments in Transferable Securities (UCITS) operating with Efficient Portfolio Management Techniques (EPM). BETTER FINANCE thanks ESMA and welcomes the action taken on consumer protection: the

Renewed research by BETTER FINANCE finds that at least 30% of the main actively managed UCITS equity funds (those with a ‘fund benchmark’) still do not comply with key disclosure requirements for benchmarks as stipulated in EU Rules. In the face of persistent poor enforcement in our view in some major fund domiciles, BETTER FINANCE

Renewed research by BETTER FINANCE finds that at least 30% of the main actively managed UCITS equity funds (those with a ‘fund benchmark’ ) still do not comply with key disclosure requirements for benchmarks as stipulated in EU Rules. In the face of persistent poor enforcement in our view in some major fund domiciles, BETTER

Last week, the European Commission published seven Notices to stakeholders concerning the Withdrawal of the United Kingdom and EU rules in the field of banking and finance, to prepare for, and soften, the upcoming shock on March 30th, 2019. Among them, professionals in the asset management sector have been warned that after the Article 50