AMAFI

AMAFI welcomes the opportunity to share its views on the revision of the Sustainable Finance Disclosure Regulation (SFDR) as part of the European Commission call for evidence. The SFDR review is expected to deliver a thorough reassessment of the framework and provides a key opportunity to address several longstanding challenges, notably: - The current exclusion of structured products from its scope, even though some…

Association française des marchés financiers (AMAFI) is the trade organisation working at national, European and international levels to represent financial market participants in France. It mainly acts on behalf of credit institutions, investment firms and trading and post-trade infrastructures, regardless of where they operate or where their clients or counterparties are located.

AMAFI welcomes the opportunity to give feedbacks on European Commission proposed amendments to delegated acts under MiFID 2 to include ESG considerations into Suitability requirements. Indeed, AMAFI pays particular attention to the development of ESG criteria in the financial markets and welcomes this objective to develop sustainable investments which are vital for our future.

AMAFI welcomes the European Commissions assessment of the prudential framework applicable to investment firms and broadly shares its conclusion that IFR/IFD generally functions well, while improvements remain possible in terms of proportionality, simplification, supervisory convergence and international competitiveness.

AMAFI strongly supports the European Commissions (EC) objective of increasing retail clients participation in capital markets to help meet the financing needs of the EU and achieve the investment objectives of EU savers.

AMAFI has the following comments on: • Product Governance Shares and bonds should be removed from the scope of Product Governance rules.These were primarily designed for structured products and their application to shares and bonds is unsuitable and does not provide added protection to retail clients while discouraging firms from distributing them to such investors.

AMAFI overall supports the proposals and the level of ambition of the Market Integration and Supervision package, our priorities are the following (further details are provided in the attached document): Trading Extraterritoriality of EU law: post-trade transparency for MiFIR instruments - Remove the duplication of reporting for all MiFIR instruments across UK and EU transparency regimes and across UK and EU…

Efficient financial markets that can effectively support the substantial financing needs of strategic sectors are essential to strengthen the Unions economy and global standing. We encourage the European Commission to adopt, in defining the necessary regulatory changes, an outcome-driven approach focused on growing EU financial markets, increasing their attractiveness to both institutional and retail investors…

AMAFI represents the financial market participants in the sell-side, established in France. The Association comprises more than 170 French and international institutions of all sizes, including investment firms, credit institutions, brokers, stock exchanges and private banks. They intervene in all market segments, including equity, bonds and derivatives, including commodity derivatives.

Filed in French · English published by the European Commission

AMAFI welcomes the opportunity to comment on ESAP draft Regulation afforded by the Commission. However, AMAFI would like to raise the Commission's attention on two specific concerns AMAFI has with ESAP draft regulation: 1.

Although AMAFI welcomed the Commission’s initiative in 2 021, it is now compelled to express its disagreement with the proposal for a DEBRA Directive, mainly because of the overlap between ‘capital allowance/limitation of interest deduction’ and the low notional interest rate chosen.

Filed in French · English published by the European Commission

As AMAFI has always encouraged equity financing for companies, AMAFI supports the introduction of an efficient mechanism to reduce the debt bias. The swift adoption of this type of measure should allow for a strengthening of the capital base that is particularly needed in the aftermath of the COVID-19 crisis.

Filed in French · English published by the European Commission

AMAFI would like to point out that legislative stability is essential. In choosing which changes to make, a balance should be struck between the expected added value of these changes, which may be minor, and the readjustments they entail for the entities concerned, which may be significant. AMAFI welcomes the exemptions to a prospectus as they are proposed in the amendments to the Prospectus Regulation.

Association française des marchés financiers (AMAFI) is the trade organisation working at national, European and international levels to represent financial market participants in France. AMAFI mainly acts on behalf of investment firms and credit institutions (French, European and global firms), operating in and/or from France (corporate and investment banks – CIBs, brokers-dealers, exchanges, and private banks).

About AMAFI. Association française des marchés financiers (AMAFI) is the trade organisation working at national, European and international levels to represent financial market participants in France. It mainly acts on behalf of credit institutions, investment firms and trading and post-trade infrastructures, regardless of where they operate or where their clients or counterparties are located.

AMAFI welcomes the opportunity to give feedback on the Commission’s Roadmap regarding its action plan on anti-money laundering and countering financing of terrorism (“AML/CFT”) and supports with the EU’s ambition on this topic. Nowadays, regarding the importance taken by AML/CFT issues, investment firms are legitimately subject to many requirements on this topic.

Association française des marchés financiers (AMAFI) is the trade organisation working at national, European and international levels to represent financial market participants in France. AMAFI mainly acts on behalf of investment firms and credit institutions (French, European and global firms), operating in and/or from France (corporate and investment banks – CIBs, brokers-dealers, exchanges, and private banks).

AMAFI has always promoted actions for the integration of European financial markets. The Commission’s work on a possible revision of the VAT rules on financial and insurance services undoubtedly contributes to this search for greater economic efficiency in favour of an integrated European market for financial services.

Filed in French · English published by the European Commission

AMAFI welcomes the opportunity to answer to this consultation.Our membership comprises sell sides entities as well as trading venues. Among the latter, some has dicentive views with regards to certain points on the CT, and the equity market structure.