EFAMA also welcomes the fact that ELTIFs are one of the key priorities in the context of the Capital Markets Union and appreciates the Commission’s intentions to further increase the attractiveness of ELTIFs to different categories of investors.
At the same time, EFAMA has been vocal on the fact that the ELTIFs Regulation should avoid an one‐size-fits all approach that would fail to address the different needs of the wide range of investors it seeks to target. Given the different needs of each investor category, as well as the different strategy and projects each ELTIF will carry, EFAMA would like to stress once more that the new Regulation needs to ensure that the interests and needs of different types of investors are met and that the right incentives are in place for EL-TIFs to become a market success.
The asset management industry would therefore be in favour of ensuring the maximum flexibility for the ELTIF framework, in particular on the eligibility of the underlying assets, the diversification rules for ELTIFs open only to professional investors, the possibility to treat certain types of investors as professional investors and the lifetime/lifecycle of the funds. Moreover, channelling investments towards infrastructure projects and SMEs will require removing existing EU and national regulatory and fiscal barriers when it comes to investing in more long-term and illiquid assets.
Therefore, EFAMA appreciates the intention to find practicable solutions in the context of the RTS and it would like to ask ESMA to apply such flexibility and adaptability in the final ESMA RTS, in order to ensure EL-TIFs will materialize their added value and increase their market potential.
© EFAMA - European Fund and Asset Management Association
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