The Association of the Luxembourg Fund Industry (ALFI) does not believe that some of the scenarios envisaged by the FSB, such as securities lending activities, if conducted in accordance with current European standards, or transfer of accounts, present a systemic risk to the functioning of markets and explain their reasoning.
ALFI also notes that a number of EU regulatory initiatives have both taken place and been initiated since the start of the recent financial crisis (e.g. AIFMD reporting, Solvency II, the UCITS Directive, MiFID, MMF Regulation and underlying guidelines from ESMA) dealing with:
Transparency of information;
Supervision of the asset management industry.
Whilst these regulatory initiatives have been in place for a relatively short time frame, there have been a number of market events which have provided some evidence of the effectiveness of these tools. ALFI would recommend that the FSB takes the impact of these initiatives into account as part of its systemic risk remit. In particular ALFI calls for more work to be conducted to assess the considerable amount of data that is being reported by asset managers to their regulators under recent regulatory developments such as AIFMD and to feed information back to the market on the aggregate trends observed.
ALFI notes that the EU is undertaking a CMU initiative, which seeks to develop capital markets such that European companies are no longer so reliant on bank financing. Rather than concentrating systemic risk in the banking sector the development of capital markets, especially when combined with ongoing transparency of positions held in investment funds, has the positive effect of spreading risk across a wide variety of asset owners with varying investment objectives and time horizons. This thereby reduces the risk of any one market event leading to material market inflows or outflows by any one set of asset owners. Various European governments have also put in place schemes which are designed to direct financing to small and medium sized businesses. Investment funds play a part in directing finance to such companies, thereby creating liquidity and diversifying the recipient’s sources of lending. Moreover, detailed rules on risk management, ring-fencing of assets etc. ensure a higher level of investor protection if investment funds are used for this purpose.
Last but not least, ALFI is of the view that the scope of the present FSB WS3 work fails to adequately account for the behaviour of direct asset-owners, i.e. large institutional investors that choose to manage their funds in-house and/or rely on the services of investment advisors/consultants. ALFI encourages the FSB to adopt a more holistic approach to monitor financial market risks by looking at a wider spectrum of actors, e.g. from the large, direct assetowners like SWFs to perhaps more remote cases where even individuals may destabilise markets.
© ALFI - Association of the Luxembourg Fund Industry
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