This response calls the EBA to introduce targeted changes to some of its technical measures to implement the prudential and remuneration rules that apply to MiFID investment firms (and which could create a precedent in an AIFMD context). Areas on which this response focuses include double-counting of assets when determining the firm’s capital requirements, the staff that is deemed to have a material impact on the firm’s risk profile and alternative arrangements that may be used to pay variable remuneration.
In this response we explain why ESMA should take into consideration the nature of private equity funds and their characteristics, including the absence of a risk of fire sales, when preparing Guidelines on limits national competent authorities can impose on their use of leverage.
In this consultation response, we emphasise the importance of respecting the principles of proportionality, materiality and flexibility, and the need to avoid a one-size-fits-all approach. In addition, we urge the European Supervisory Authorities to recognise the lack of available data for non-listed companies, in particular SMEs, and the limited relevance of many proposed indicators given the large diversity of economic sectors invested in by PE/VC funds.
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.
Public Affairs Director
Senior Public Affairs Manager
Public Affairs Officer
Sofia Garrido Perez
Public Affairs Officer
Public Affairs Manager
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