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24 October 2016

ALFI's response to the EU Commission consultation “Review of the EU macroprudential framework”


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Bearing in mind that almost all questions ask for feedback from stakeholders on the existing ESRB / ECB system which is targeted to banks, ALFI has focused in its response on question 2 regarding a potential expansion of the macroprudential framework beyond banking.


Association of the Luxembourg Fund Industry (ALFI) pointed out that asset management and fund related activities do not entail structural vulnerabilities and that the sector is already highly regulated by regulations such as the UCITS Directive, AIFMD, Solvency II, MiFID, EMIR or the Securities Financing Transactions Regulation, dealing with both transparency of information and supervision of the asset management industry.

Moreover, ALFI stated that investment funds contain characteristics that differentiate them from banks.

Therefore, ALFI believed there should be little distress to the wider financial system in the event of the default of an individual asset manager given the high degree of competition and substitutability within this sector.

Overall, ALFI was of the view that it is inappropriate to expand the macro-prudential framework beyond banking to asset managers and investment funds.

Full response



© ALFI - Association of the Luxembourg Fund Industry


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