The French asset management association (AFG) welcomes the initiative of the Market Integration and Supervision Package aiming at promoting simplification, tackling barriers to cross-border activities and contributing to shape a more integrated European Union. AFG takes the opportunity to develop its views on the various topics developed in this initiative in the attached document.<\/p>\n\n\n\n
1. AFG strongly supports the introduction of a competitiveness mandate for ESMA, as a necessary counterpart to its increased regulatory powers. <\/strong>Developing more integrated and competitive EU capital markets should also be based on monitoring the respective market share of EU based financial industry in the EU and beyond, compared with non-EU headquartered financial market participants.<\/p>\n\n\n\n 2.<\/strong> AFG supports many of the proposals made in favor of tackling barriers to cross-borders activities<\/p>\n\n\n\n 3.<\/strong> AFG welcomes simplifications of intra-group and intra-EU delegation arrangements, namely the acknowledgement at Level 1 that intra-EU intra-group arrangements require lower oversight and substance than extra-group arrangements. Those simplifications need to encompass broadly all asset management business models, which is not the case of the current reference to the Accountability directive. <\/strong>Nevertheless, the current proposal continues to present areas of uncertainty and calls for additional clarification: therefore, this paper explores different options<\/strong> that could be contemplated.<\/p>\n\n\n\n 4.<\/strong> AFG supports an enhanced role for ESMA but it should be based on an increased supervisory convergence as well as true Data Hub <\/strong>(to accompany ESAP development). But AFG cautions introducing a top-down<\/strong> more integrated supervision<\/strong>, asit could create an additional layer of oversight, undermining the aim of simplification of the SIU.AFG questions the opportunity of the ESMA periodic review, that should not translate in any additional burden for the industry and would not be in favour of proposals aimed at giving ESMA direct supervisory powers over asset management companies, as this may lead to an additional layer of supervision bringing the industry to face complexity, an unclear and inefficient supervisory architecture (overlap between national v. EU supervisors for instance) and costs, which would harm EU actors\u2019 competitiveness. Introduction of ESMA datahub to collect and share data between ESMA and NCAs should be a preliminary step before envisaging this type of review.<\/p>\n\n\n\n 5. <\/strong>With respect to ESMA governance, AFG asks that supervisory costs be closely monitored and lowered (and not the opposite)<\/p>\n\n\n\n 6.<\/strong> AFG strongly supports the European Commission\u2019s (EC) decision not to propose radical changes to the current equity market structure framework, which is effective for investors. Regulatory stability must come first and any adjustments should follow a rigorous, evidence-based impact assessment.<\/p>\n\n\n\n 7.<\/strong> AFG also supports the EC\u2019s proposal to enhance pre-trade transparency on the equity and ETF consolidated tape by including the venue identification and the five levels of the order book. Moreover, to ensure strong user uptake from the start, we urge rapid implementation, rather than deferring these improvements until the next provider tender in 2031.8.<\/strong> AFG welcomes measures to enhance interoperability between market infrastructure and trading venues. Moreover, we believe that interoperability between TVs and CCPs should be strengthened and mandated to deliver tangible benefits.<\/p>\n","protected":false},"excerpt":{"rendered":" The French asset management association (AFG) welcomes the initiative of the Market Integration and Supervision Package aiming at promoting simplification,…<\/p>\n","protected":false},"author":35,"featured_media":116804,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":true,"_gspb_post_css":"","wds_primary_category":1,"footnotes":""},"categories":[1],"tags":[],"thematics":[481,183,703,658],"top_contenu":[568],"class_list":["post-124367","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-non-classe","thematics-competitiveness","thematics-reglementation_europeenne_et_internationale","thematics-simplification","thematics-siu","top_contenu-top-contenu-commission-club"],"acf":[],"_links":{"self":[{"href":"https:\/\/www.afg.asso.fr\/en\/wp-json\/wp\/v2\/posts\/124367","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.afg.asso.fr\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.afg.asso.fr\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.afg.asso.fr\/en\/wp-json\/wp\/v2\/users\/35"}],"replies":[{"embeddable":true,"href":"https:\/\/www.afg.asso.fr\/en\/wp-json\/wp\/v2\/comments?post=124367"}],"version-history":[{"count":0,"href":"https:\/\/www.afg.asso.fr\/en\/wp-json\/wp\/v2\/posts\/124367\/revisions"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/www.afg.asso.fr\/en\/wp-json\/wp\/v2\/media\/116804"}],"wp:attachment":[{"href":"https:\/\/www.afg.asso.fr\/en\/wp-json\/wp\/v2\/media?parent=124367"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.afg.asso.fr\/en\/wp-json\/wp\/v2\/categories?post=124367"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.afg.asso.fr\/en\/wp-json\/wp\/v2\/tags?post=124367"},{"taxonomy":"thematics","embeddable":true,"href":"https:\/\/www.afg.asso.fr\/en\/wp-json\/wp\/v2\/thematics?post=124367"},{"taxonomy":"top_contenu","embeddable":true,"href":"https:\/\/www.afg.asso.fr\/en\/wp-json\/wp\/v2\/top_contenu?post=124367"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}