EFAMA in its comments to the European Commission’s Green Paper on investment funds urges the Commission to present new regulatory initiatives if it is to realise the goals of the review, i.e. advancing the single market for investment funds, including a level playing field for all savings/investment products, fostering investor protection and enhancing the efficiency of the industry.
EFAMA shares the Commission’s view that much can be done to facilitate the successful development of the fund industry in Europe by building on existing legislation, in particular the UCITS Directive and MiFID. Simplifying registration procedures and turning the simplified prospectus into a short, easily understandable and comparable fact sheet are of immediate importance.
Other issues that would require significant changes to current regulation include:
possibilities for cross-border mergers and pooling;
a “real” passport for the management company;
a level playing field in competing saving products both at the levels of distribution and production, in order to ensure consistent investor protection;
reshaping the product passport to eliminate notification entirely;
making the UCITS Directive “Lamfalussy-conform” to make it more flexible and facilitate innovation;
in the longer term, reshaping the regulatory architecture for investment
management.
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© EFAMA - European Fund and Asset Management Association
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