Events listed in [ALFI] Association of the Luxembourg Fund Industry
ALFI responds to the European Commission’s consultation regarding the proposal for ...
ID 24811
ALFI has responded to the European Commission’s request for feedback on the proposed regulation on the transparency and integrity of ESG rating activities. ALFI generally welcomes the proposed regulation but has some specific comments and suggestions. ALFI suggests that certain cases should be exempted from the regulation’s rules, including ESG ratings shared within a group, internal ESG assessments of investments for internal use, ESG ...
ALFI submits a position paper on the European Commission proposal on a retail ...
ID 24759
The ALFI has expressed its position on the European Commission’s proposal for a retail investment package, which includes the Omnibus Directive and the PRIIPs Regulation. ALFI believes that the proposal has some positive elements, but also raises concerns about certain provisions that could negatively impact investors and stifle innovation. **One of the main concerns is the use of benchmark assessments to evaluate the value ...
ALFI responds to ESMA RTS under the revised ELTIF Regulation
ID 24720
ALFI responded to the ESMA Consultation Paper on the draft regulatory technical standards under the revised ELTIF Regulation, providing detailed feedback on various aspects of the proposed regulations. Regarding the assumptions made in relation to the ELTIF cost ratio figures, ALFI suggests that these assumptions need to be reworked to consider the specificities of the alternative asset classes in which ELTIFs invest. ALFI also ...
ALFI responds to IOSCO’s consultation report on policy recommendations for ...
ID 24342
ALFI responded to IOSCO’s Consultation Report on Policy Recommendations for Crypto and Digital Asset Markets on 21 July 2023. The IOSCO report aims to align requirements for crypto and digital asset trading and custody with traditional financial markets globally. It includes 18 recommendations primarily for CASPs (crypto assets service providers) and covers 21 questions related to CASP activities in the crypto and digital asset ...
ALFI responds to the ESAs consultation regarding RTS on the Sustainable Finance ...
ID 24034
On 4 July 2023, ALFI responded to the ESAs consultation on the Review of SFDR Delegated Regulation regarding PAI and financial product disclosures and offered feedback on various proposals. The ESAs sought input on extending the list of universal social indicators for disclosing the adverse impacts of investment decisions on the environment and society. ALFI emphasized the importance of considering the data challenges and ...
ALFI responds to ESAs consultation on DORA criteria for critical ICT Third-party ...
ID 23844
ALFI responded to the ESAs‘ consultation on DORA criteria for critical ICT third-party service providers and oversight fees. The ESAs (EBA, EIOPA, and ESMA) initiated level 3 discussions on 26 May 2023, introducing a joint Discussion Paper to gather stakeholders‘ input on DORA. The paper addressed two technical aspects: identifying critical ICT third-party service providers and determining the payment amount to the Lead overseer. ...
ALFI response to the EC consultation on the proposal for a Council Directive ...
ID 22983
ALFI provided its opinion on the proposed Council Directive amending Directive 2011/16/EU on establishing improved collaboration among national tax authorities regarding the sharing of information related to crypto-assets (DAC 8). ALFI supports the need to improve the existing framework for exchange of information and administrative cooperation in the EU in relation to crypto-assets. ALFI has analyzed the DAC 8 text with a view to ...
ALFI response to ESMA’s consultation on the review of the methodology ...
ID 22937
ALFI has responded to the the ESMA consultation on the review of the methodology included in the Guidelines on stress test scenarios under the MMF Regulation. ESMA’s consultation period ended on 28 April 2023 and is related to a proposed update of the stress-testing methodologies applicable in the context of Article 28 of the MMF Regulation. ALFI **generally supports the use of data by ...
ALFI statement on proposed changes to Luxembourg fund laws
ID 22464
ALFI published an opinon on Luxembourg’s Parliament introduction of a new draft law aimed at improving and modernising the country’s investment toolbox, affecting five sectoral laws, namely the laws governing SICARs, SIFs, RAIFs, UCI Part II Funds, and AIFMs. Some of the proposed changes include extending deadlines to reach minimum capital, offering additional structuring options for UCI Part II funds, allowing AIFMs to **use ...
ALFI provides feedback to the European Commission on the EMIR 3 Review
ID 22305
ALFI provided feedback to the EC measures to further develop the EU’s CMU to make EU clearing services more attractive and resilient, supporting the EU’s open strategic autonomy and preserving financial stability (COM(2022) 697 final alias 2022/0403 (COD)). ALFI expressed gratitude to the EC for the opportunity to provide feedback on this clearing package, which consists of a regulation and a directive, following a ...