Assogestioni

Position on the on the proposed EU Inc. / 28th regime Regulation Assogestioni 1 welcomes the objective of strengthening the competitiveness of the EU, supporting company growth and reducing fragmentation in the internal market.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Assogestioni welcomes the European Commissions efforts to simplify and streamline the ESRS with the objective of making sustainability reporting more proportionate, operational and easier to apply. However, simplification should not come at the expense of the core purpose of the ESRS framework, ensuring the availability of clear, relevant, reliable, comparable, traceable and decision-useful sustainability…

Assogestioni supports the ECs aim to enhance clarity, coherence, and usability of SFDR. The review should align with the broader EU sustainable finance framework and prescribe disclosure which is decision-useful for retail investors and less burdensome for FMPs.

Assogestioni welcomes the growing focus on ESG transparency: we are of the view that an enhanced transparency would contribute to raising awareness among investors and encourage a positive competition among asset managers in the integration of sustainability considerations in their investment choice.

Assogestioni, the Italian asset management association, would like to express its appreciation and support to the Action plan and the proposed legislative action as a tool to achieve a transition toward a more sustainable financial system. As for the specific proposal, Assogestioni regards the definition of a taxonomy as a founding base on which to build a clearer and stronger framework for sustainable investing.

Assogestioni fully supports a number of the proposed measures while is of the view that others raise critical issues, also stemming from the extensive referral to Level 2 implementing rules, the impacts of which are currently difficult to assess.

Assogestioni expresses its appreciation for the initiative of the European Commission aimed at simplifying and streamlining key aspects of the Union legislative framework governing asset management within the Market Integration and Supervision Package (MISP).

Assogestioni expresses its appreciation for the initiative of the European Commission aimed at simplifying and streamlining key aspects of the Union legislative framework governing asset management within the Market Integration and Supervision Package (MISP).

Assogestioni shares the Commission's objective, pursued with the Proposal, to promote digital transformation and adoption of data-driven business models in the EU financial sector, by facilitating access of data to certain categories of customer data in financial services.

Assogestioni, the Italian asset management association, would like to express its full support to the European Commission with regards to the proposal of regulation ESG rating and would like to thank the EC for the opportunity to contribute to the development of said regulation.

Assogestioni strongly believes in the need of a regulatory framework that can ensure that sustainability reporting standards for companies are complete, clear and useful in identifying and assessing the impact of their activities on workers, communities, consumers and the environment, impacts often related to the specificity of the sector to which the company belongs.

Assogestioni welcomes the proposal of the Commission for the review of the ELTIF Regulation which, taking into account most of the considerations of the Association, identifies measures aimed at improving the attractiveness of ELTIFs by making them more flexible, in terms of investment policy and redemption policies, and more accessible to retail investors.

Assogestioni, the Italian investment management association , share the objective of the Commission to contribute to a wider research coverage for SMEs and increase their visibility for investors. The amendment of the current regime for research on small and mid-cap issuers with the introduction of an optional regime and a broader definition of an SME are positive steps forward.

Assogestioni supports the European Commission's approach of ensuring harmonised rules throughout the internal market with the proposed Regulation (AML Regulation) and establishing a new Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA).

Overall, Assogestioni welcomes the Commission’s proposal for the revision of the AIFM and UCITS Directives, except for some considerations with reference to the new proposals on the subject of a) delegation; b) loan originating funds; c) liquidity management tools; d) supervisory reporting; e) disclosure to professional investors. For more details, please see the Position Paper attached to this feedback.