Amundi

Amundi believes that the European Commission (EC)s proposed revision of the Sustainable Finance Disclosure Regulation (SFDR) constitutes a resolute first step in the right direction. We commend the introduction of a simple and clear categorisation system for ESG financial products & the inclusion of restrictions on uncategorised products with regard to the mention of the consideration of sustainability factors or…

AMUNDI totally supports the efforts of European co-legislators towards financing a more sustainable economy. The Sustainable Finance Disclosure Regulation (SFDR) framework has been in application for a few years now and we already see a positive impact. Its implementation has however been raising numerous challenges and concerns among authorities, financial market participants and investors.

(1) Amundi agrees that we need to have, at least at the EU level, a common language and understanding of what sustainable investment means. Otherwise national regulators may develop various approaches using different concepts and priorities that would make it impossible for investors to understand and compare.

Please find below the general comments of Amundi and read the attached document for further detail. (1) The application date of the proposed regulation is foreseen 1 year after the date of publication in the OJ. But some RTS and delegated acts are due to be drafted by ESAs within 18 months of the entry into force, i.e, 18 months and 20 days after the publication in the OJ.

(1) In Amundi’s view, the more general aim of introducing ESG references in Benchmarks Regulation (BMR) should appear in the title of the proposed regulation. We suggest the : “…amending Regulation (EU) 2016/11 on low carbon benchmarks, positive carbon impact benchmarks and disclosure by administrators on integration of ESG considerations in the methodology of their benchmarks.” (2) In recital 15, we read that the…

Sustainable finance is a clear priority within Amundi. Amundi offers a large range of funds incorporating ESG criteria, with a particular focus on Environmental factors and low carbon portfolios. For example Amundi founded with EDF a management company, Amundi energy transition, dedicated to efficient energy finance.

Amundi welcomes the European Commissions (EC) intention to empower consumers to invest in capital markets. Among the measures proposed by the EC in its Retail Investment Strategy (RIS) package, some of them are undoubtedly going in the right direction, notably the extension of the professional clients opt in under MiFID, the focus on financial literacy or the regulation of fin-fluencers.

Amundi is the largest European asset manager by assets under management and amongst the top 10 globally. It manages around 2,000 billion euros of assets across six main investment hubs in Boston, Dublin, London, Milan, Paris and Tokyo.

AMUNDI strongly supports the review of ELTIF aimed at increasing retail engagement in long term products. In line with the recommendations of the High Level Forum on Capital Markets Union. We believe that key areas to improve ELTIF are: i) enlarging eligible investments, (ii) easing the retail distribution challenges by removing quantitative thresholds to investments (iii) granting ELTIF tax neutrality.