The European Commission has published proposals to strengthen the Capital Markets Union. These include the review of the AIFMD, MiFIR, ELTIF framework and the implementation of a European Single Access Point (ESAP).

Review of the AIFMD

The BVI welcomes that the European Commission wants to harmonise essential elements of the UCITS and AIFM Directives, such as reporting and liquidity management. The European Commission shows a sense of proportion by not wanting to significantly change the already strict rules on outsourcing. ESMA has a special role to play in harmonising supervisory practices and conducting peer reviews. The BVI supports the approach that a toolbox should be available for liquidity management and that asset managers should be required to select at least one tool for each fund. The proposals on reporting can help to reduce the operational burden for both asset managers and authorities.

Review of the MiFIR

The BVI supports the European Commission's proposed consolidated tape for equity and bond prices. This tape improves market transparency, increases data quality, and can help to reduce costs for all market participants. However, the consolidated tape alone does not solve the problem of rising market data prices. Moreover, it is essential that exchanges, and other trading venues have to report harmonised data monitored by ESMA.

Review of the European Long-Term Investment Funds (ELTIF) framework

The BVI welcomes that the European Commission has considered some of its proposals to streamline the ELTIF regulation. However, it remains to be seen whether the proposed simplifications such as the deletion of the minimum investment amount of EUR 10,000 and the removal of the additional suitability test, will be sufficient to make the ELTIF a market success.

Proposal for a European Single Access Point (ESAP) Regulation

The implementation of an ESAP is an important step to improve the availability of data for fund companies and to be able to fulfil the increasing reporting obligations in a more cost-effective way. The use of the ESAP will depend on its technical design. Together with the German Insurance Association, the BVI has presented concrete proposals for this. It is good that the use of ESAP data is to be free of fees and licences.