In this response we argue that changes should be made to the definition of a "professional investor upon request" to better acknowledge the features of long-term & sophisticated investors in asset classes such as private equity. We also describe to the European Commission our concerns with the current retail disclosure documents, which are too standardised to give investors an appropriate idea of the real risk and benefits of long-term investments.
This long awaited official Guidance from the European Commission clarifies the application of the Sustainable Finance Disclosure Regulation (SFDR). From our industry’s perspective, the letter clarifies that SFDR does apply to all AIFMs carrying out activities in the EU (including those gaining access through NPPRs), and clarifies the definitions of Article 8 and 9 products.
In this response, we comment on changes that have been introduced by the European Commission as well as present our own suggestions for Guidelines to fully play their role in allowing Member States to deliver aid to innovative and growing companies by providing targeted support to the private venture and growth funds that invest in them.
Ahead of the forthcoming AIFMD review, Invest Europe joined forces with other trade associations, such as AIMA, ACC and Inrev, to express our concerns to the European Commission on any changes policymakers are considering making to the AIFMD delegation regime. The letter explains, among others, how the EU benefits from the global nature of the fund management industry and that the EU fund management regulatory framework is robust and fit for purpose.
In our response, we welcome the Commission’s proposal for a CSRD and support the view that in order to achieve sustainable and inclusive growth it is key to have relevant, comparable and reliable sustainability information. That said, we ask the Commission to pay particular attention to certain aspects of the CSRD of key importance to the industry, such as the need for alignment, coherence and consistency on content and timeline with other pieces of legislation, such as the SFDR and the Taxonomy, and the importance of applying the materiality and proportionality principles when considering the extension of the scope to SMEs.
In this response, we shared our views on the European Commission’s initiative to mitigate a potential debt-equity bias induced by taxation. We notably stressed that the differences between the tax deductions of costs related to debt vs. equity should be dealt with in a way that allows for more deductions – not fewer. Thus, we are happy to support the idea of introducing an equity allowance.
This Q&A addresses the treatment of an institution’s investments into EU AIF managed by a non-EU AIFM and into closed-ended CIUs, flagging that clarification should be brought to such treatment to ensure that exposures to closed-ended funds are not given a risk weight that is not appropriate to the risk it poses.
This letter, as for the Q&A to the EBA, addresses the treatment of an institution’s investments into EU AIF managed by a non-EU AIFM and into closed-ended CIUs.
Neil Griffiths (ERM), Maaike van der Schoot (AlpInvest Partners), Martina Sanow (Hg), Anna Follér (AP6) and Claus Asbjørn Andersson (Sunstone Life Science Ventures) joined our Diversity Webinar on 21 June to share insights and practical examples on how they approach diversity at GP, LP and portfolio company levels. The recording of the webinar is available in the Members' Policy Call section of the website. The results of the poll on DE&I practices in the industry undertaken during the webinar can be found here.
In this paper Insurance Europe and Invest Europe jointly present their suggestions on how to allow insurers to commit capital into long-term funds such as private equity ones. The document also gathers specific changes to the criteria of the Solvency II recently introduced long-term equity category.
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