BVI

BVI welcomes the EU Commissions initiative to update and simplify the technical screening criteria under the EU Taxonomy in order to reduce complexity and to enhance the Taxonomy relevance for investment decisions. Our remarks focus on the recommendations for real estate activities, in particular the activity 7.7 acquisition and ownership of buildings.

As users of ESG data, BVI members highly value the benefits of standardised sustainability reporting under the ESRS. Data reported by companies is more accurate, timely and low-cost for investors than information obtained from commercial ESG data vendors and more reliable due to the assurance requirement.

BVI welcomes the opportunity to provide its views on the European Commission’s proposal laying down harmonised rules on artificial intelligence. The use of artificial intelligence (AI) and machine learning (ML) in asset management bears great potential.

BVI supports the EU initiative for establishing binding rules on sustainable corporate due diligence. Already in 2013, the German fund industry agreed on common principles for responsible investing that have since then been enshrined in chapter V of the BVI Rules of Conduct2.

BVI welcomes the opportunity to submit initial views on the envisaged measures to promote sustainable corporate governance in EU companies and to ensure that sustainability is further embedded into the corporate governance framework. Please find our comments in the document attached.

BVI supports the EU Commissions initiative to update and simplify the technical screening criteria under the EU Taxonomy. With regard to real estate activities, we welcome the improved alignment between the EU Taxonomy criteria and the Energy Performance of Buildings Directive (EPBD).

BVI welcomes the EU reform of the SFDR framework and applauds the EU Commission for bringing forward a proposal that is considerate of both, safeguarding ambition of ESG-related investment strategies and the need for ensuring continuity and building upon approaches and standards already implemented in the market.

1. Product classification: We support the establishment of a voluntary system of product categorisation based on the sustainability propositions of financial products. We recommend distinguishing three product categories in correspondence to the PSF proposal: - Focus on positive contribution to an environmental/social objective (sustainable): This category would encompass products that aim at making a measurable…

Encouraging investments in sustainable products is a core element in the strive towards a more sustainable environment. Therefore, BVI is supportive of the European Commission’s Action Plan and the legislative proposals on Financing Sustainable Growth.

Encouraging investments in sustainable products is a core element in the strive towards a more sustainable environment. BVI therefore welcomes the European Commission’s Action Plan and in particular the aim to build a classification for sustainability (“Taxonomy”). A common language and disclosure building on such common language have the potential to facilitate a shift towards a more sustainable environment.

Encouraging investments in sustainable products is a core element in the strive towards a more sustainable environment. BVI (BVI represents the interests of the German fund industry at national and international level. The association promotes sensible regulation of the fund business as well as fair competition vis-à-vis policy makers and regulators.

Encouraging investments in sustainable products is a core element to move towards a more sustaina-ble environment. BVI (BVI represents the interests of the German fund industry at national and international level. The association promotes sensible regulation of the fund business as well as fair competition vis-à-vis policy makers and regulators.

BVI’s view on responsible investment Responsible and long-term considerations play an increasingly important role in investment decisions. Many investors feel a responsibility to address environmental, social and governance (ESG) issues by being more selective in their investments. The asset management industry plays a crucial role in facili-tating this trend.

BVI position on the European Commission's proposal for the "Corporate Sustainability Reporting Directive" (CSRD) The revision of the EU framework for non-financial reporting is key to achieving the objectives of the EU Action Plan on Financing Sustainable Growth.

As representatives of the German fund industry, we consider it essential to obtain reliable, standardised and comprehensive information from companies on sustainability-relevant matters. Asset managers and institutional investors will only be able to pay due consideration to sustainability aspects when taking investment decisions if such information is readily available and comparable across different companies and…

BVI, the German investment funds association, supports the Commission's stated goal of broader participation of retail clients in the capital markets. It is essential to encourage private investors to benefit from the opportunities of the capital markets. However, we feel that many of the proposals are not helpful for achieving this goal, while some others are probably outright counterproductive.

We welcome the goal of reinforcing the participation of retail clients in the capital markets. This is particularly necessary due to the low interest rate environment and, in particular, for funded retirement provision. However, we believe it is necessary to carefully examine which measures help and which, if any, may be more of a deterrent for customers or are not advisable in light of a cost-benefit comparison.

BVI and its members are committed to shaping a competitive EU Single Market for financial services and dismantling the remaining obstacles to effective cross-border operations. Hence, while supporting the political objectives of the Market Integration Package, it is important that the specific policy measures remain targeted and proportionate, addressing genuine obstacles without introducing additional complexity or…

BVI and its members are committed to shaping a competitive EU Single Market for financial services and dismantling the remaining obstacles to effective cross-border operations. Hence, while supporting the political objectives of the Market Integration Package, it is important that the specific policy measures remain targeted and proportionate, addressing genuine obstacles without introducing additional complexity or…

BVI welcome the EU proposal for a Regulation on the transparency and integrity of Environmental, Social and Governance (ESG) rating activities which appears suitable for improving the quality of information on ESG ratings and addressing the existing shortcomings in the ESG rating market.

We fully support the EU initiative for establishing a single EU access point for company information. Such centralised point of access would be very helpful for asset managers in order to be able to easily obtain important information on their investee companies, in particular on ESG topics.

We embrace the EU Commission aim to review the CSDR. We welcome the Commission proposal to improve the mandatory buy-in (MBI) regime as it takes generally into consideration the market feedback provided by the relevant stakeholders (e.g. Asset Manager).

BVI welcomes the initiative by the EU Commission to review the regulatory regime of CSDR. German investment fund managers acting on behalf of regulated investment funds (UCITS/AIFs) are important users of the securities markets in the EU. German investment fund management companies are not directly involved in the value chain of clearing and settlement of securities transactions.

The BVI gladly takes the opportunity to contribute to the inception impact assessment by sharing its views on the current ELTIF regime considering the upcoming review of the Regulation. Please find our full response attached. The raison d'être of the ELTIF Regulation should be to address specific areas for which there are not yet sufficiently specialised fund products in the EU to achieve the desired objectives.

BVI welcomes the opportunity to respond to the proposal amending delegated directive (EU) 2017/593 as regards the regime for research on small and mid-cap issuers (SME) and on fixed-income instruments to help the recovery from the COVID-19 pandemic.

We support the goal of the EU Commission to further streamline the EU framework for indices and (“critical”) benchmarks. The BMR helps to strengthen the confidence in the financial markets and helps to prevent manipulation of financial indices. Investment funds are highly regulated and transparent financial products under the UCITS/AIFM regime.

We highly appreciate the work started by the EU Commission to review the BMR. We are supportive to further modernise the regulatory framework of the IBORs and the Third Country Benchmarks. However, during the past years our members have observed significant increase of costs related to the use of indices, especially the access to the underlying data.

In the EU, a total of €12.8 trillion is invested in investment funds by private and institutional investors. With assets of €3.4 trillion in UCITS and AIFs, Germany is the largest market with a share of 27 per-cent. In terms of funds launched in the EU, the German AIF market accounts for EUR 2,218 billion out of EUR 6,878 billion in the EU, which corresponds to a share of 32.2 percent.

With assets of EUR 3,000 billion, Germany is the largest market in the EU (according to the ECB as of 30 June, 2020) with a market share of 27 percent. In a context of continued inflows and growth of the asset management sector, financial stability bodies such as the European Systemic Risk Board (ESRB) and the European Central Bank (ECB) have called for an impact assessment of the resilience of the current framework…

BVI would like to take this opportunity to provide its views on the proposed framework for the pilot regime for market infrastructure based on distributed ledger technology (DLT). An EU regulatory framework should provide a level playing field between crypto and traditional investments in terms of transparency / disclosure obligations as well as risk management for the benefit of investor protection.

BVI would like to take this opportunity to provide its views on the proposed framework for markets in crypto-assets (MiCA). An EU regulatory framework should provide a level playing field between crypto and traditional investments in terms of transparency / disclosure obligations as well as risk management for the benefit of investor protection.

BVI fully supports this important initiative. The entire financial market will be significantly influenced by the increased availability of data, algorithms, the digitalisation of assets, new processes in custody and settlement, and reporting.

We, the BVI as the German Investment Funds Association and the German Banking Industry Commit-tee (GBIC), take the opportunity to present our views on the CMDI package proposed by the Europe-an Commission in relation to the proposal for a Directive amending Directive 2014/49/EU (Deposit Guarantee Schemes Directive, DGSD) as regards the scope of deposit protection.

General remarks BVI sees great value in the creation of four asset class based consolidated tapes (equities, ETFs, bonds, derivatives) to support Europe’s capital markets. However, we qualify that statement with a reminder that the framework for a successful consolidated tape should i) address the known market failure around market data costs, ii) manage the costs of the tape by limiting compensation for data…