Association of the Luxembourg Fund Industry (ALFI)

The Association of the Luxembourg Fund Industry (ALFI), responding to this consultation from the perspective of investment funds managers and fund management companies, is providing comments, proposing alignments between regulatory requirements and clarifications, as well as raising some concerns to be considered as the views of the Luxembourg investment fund industry, in a segment focused on cross-border…

Feedback on the proposal Scope: - The scope of the proposal captures different sectors and entities. While it is clear that a common set of rules should apply to the commercial sector, it should be kept in mind that for financial institutions and in particular asset managers (AMs) the supply - and investor chain are not on equal terms. Reg.

ALFI supports the European Commissions (EC) ambition to simplify the SFDR framework by reducing administrative requirements, improving clarity for end investors and strengthening the frameworks coherence. We welcome in particular: - The exemption for funds closed before the application date of SFDR 2.0. - In principal, the establishment of three main distinct categories.

We thank the European Commission (EC) for the opportunity to participate in its call for evidence on the review of the SFDR and welcome the ECs ambition to simplify and streamline the SFDR. There remain diverging views in the market, however, as SFDR has contributed to increased transparency, investors have become accustomed to the current regime and financial market participants (FMPs) have invested substantial…

ALFI has been at the forefront of actively promoting sustainable finance opportunities for asset managers. ‘Responsible Investing’ is a major pillar of the Luxembourg investment fund industry and ALFI firmly believes that asset managers can play a key role in this area.

ALFI has been at the forefront of actively promoting sustainable finance opportunities for asset managers. ‘Responsible Investing’ is a major pillar of the Luxembourg investment fund industry and ALFI firmly believes that asset managers can play a key role in this area.

Introduction The Association of the Luxembourg Fund Industry (ALFI) is the representative body of the Luxembourg investment fund community. Created in 1988, the Association today represents over 1,400 Luxembourg domiciled investment funds, asset management companies and a wide range of service providers such as depositary banks, fund administrators, transfer agents, distributors, legal firms, consultants, tax…

ALFI warmly welcomes the CSRD proposal that will ensure that much more ESG reliable data are available in the European market. This is key to enable FMPs to satisfy their reporting duties under SFDR. We are nevertheless concerned about the application timeline: per the current timetable, CSRD reports will be available at best in 2024 (in respect of the 2023 financial year), whereas SFDR reporting requirements will…

Omnibus directive: To protect investors from being affected by excessive costs and services not aligned with their investment objectives or not offering any added value, as well as from potential conflicts of interests, ALFI believes that it is crucial to offer a clear, transparent overview of costs, their structure and services attributed.

Referring to the ALFI response to the EC consultation strategy for retail investors, we propose the EC to perform targeted modifications of legislation especially in the following areas: Investor categories - We welcome the EC’s intention to tackle overly restrictive protective measures for investors with sufficient knowledge and experience.

As was highlighted in the Draghi and Letta reports, the key objectives of the Savings and Investment Union (SIU) should be the mobilization of European retail savings into productive investments and the development of supplementary (funded) pensions as the two most important levers to create deeper capital markets.

The Association of the Luxembourg Fund Industry (ALFI) represents the face and voice of the Luxembourg asset management and investment fund community. The Association is committed to the development of the Luxembourg fund industry by striving to create new business opportunities, and through the exchange of information and knowledge.

The Association of the Luxembourg Fund Industry (ALFI) thank the European Commission for the opportunity to provide feedback on the EC proposal for a regulation on the transparency and integrity ESG rating activities. ALFI generally welcomes the proposed regulation. Nonetheless we would like to comment on particular aspects as follows.

ALFI welcomes the public consultation on the proposal for a Council Directive on Faster and Safer Relief of Excess Withholding Taxes released on 19 June 2023 and introducing a new EU system for the avoidance of double taxation and prevention of tax abuse in the field of withholding taxes (the draft Directive).

Firstly, we would like to share the following observations on the application of the cash penalty regime a. From the monitoring that has been performed since the application of the cash penalty regime on 1 February, it appears - if cash penalties are to be passed on - that investment funds should receive a net credit balance, which is logical as they are net buyers of securities.

The Association of the Luxembourg Fund Industry (ALFI) is the representative body of the Luxembourg investment fund community. ALFI appreciates the opportunity to provide its views on the debt-equity bias reduction allowance (DEBRA) as proposed by Council Directive laying down rules on a debt-equity bias reduction allowance and on limiting the deductibility of interest for corporate income tax purposes (the draft…

The Association of the Luxembourg Fund Industry (ALFI) welcomes the opportunity to provide feedback on the proposed Council Directive laying down rules to prevent the misuse of shell entities for tax purposes and amending Directive 2011/16/EU. Please find our comments in the attached file.

ALFI supports the European Commission’s efforts to fight money-laundering and financing of terrorism and is in favour of harmonising further certain professional obligations of European financial industry stakeholders. This is to the benefit of the Luxembourg fund industry, which is largely cross-border.

With around 700 sub-threshold alternative investment fund managers (AIFMs) and 30 EuVECA funds/17 EuVECA managers, Luxembourg is a popular choice of domicile for small and mid-sized AIFMs in the EU. However, compared to the number of market participants operating in the US venture capital ecosystem (3111 VC firms in 2024), the numbers in Europe are small overall.

The Association of the Luxembourg Fund Industry (ALFI) supports the need to improve the existing framework for exchange of information and administrative cooperation in the European Union in relation to crypto-assets.

1. Intragroup: We welcome the new measure that simplifies the applicable regime. 2. CO/PSAs: We welcome the clearing exemption for transactions entered into with a PSA established in a third country which is exempted from the clearing obligation under its national law. 3. CO for FCs: We welcome the new calculation formula where only contracts that are not cleared at a CCP should be included.

We thank the European Commission for the opportunity to provide feedback on the legislative proposal concerning the review of the Alternative Investment Fund Managers Directive (AIFMD). ALFI welcomes the targeted nature of the review.

We thank the European Commission for the opportunity to provide feedback on the inception impact assessment concerning the review of the Alternative Investment Fund Managers Directive (AIFMD). According to this impact assessment, the major focus of the review should be on the directive’s effectiveness and the aim of completing a single market for AIFs in the context of the Capital Markets Union (CMU).