News

Regulations

Federal Ministry of Finance addresses key MiFID and PRIIPs requirements for the financial sector

The MiFID II and PRIIPs debate has finally moved on. The German government has acted on the financial sector’s main criticisms and is now calling upon...more...

Sustainability | Regulations

BVI on the latest ESG Taxonomy TechReport

The good news is that the expert group does not want to limit the classification system to 100 percent "green" activities, but allows gradations. This...more...

EU Regulation | Regulations

Thomas Richter: Why a common European Single Market is not the answer

Some representatives of the European Union are convinced that a European Single Market with the greatest uniformity possible can provide a cure-all...more...

BVI states its views

As a centre of competence and central contact point in developing and applying new legal regulations, BVI mediates between the investment industry and politicians. BVI issues statements on current changes in both the legal and taxation frameworks.

Some BVI statements on international legislators are issued in English. These are available as follows:

6/9/2019
MiFID II/MiFIR review report on the development in prices for pre- and post-trade data and on the consolidated tape for equity instruments

28/6/2019
BVI’s response to the ESMA Consultation Paper on draft regulatory technical standards under Article 25 of the ELTIF Regulation

6/5/5019
Introduction of an EU Ecolabel for financial products

3/4/2019
Feedback on the TEG preliminary recommendations for an EU Green Bond Standard

1/4/2019
BVI’s response to ESMA’s consultation paper regarding guidelines onliquidity stress testing in UCITS and AIFs

29/3/2019
Targeted consultation on market liquidity in foreign exchange markets

22/2/2019
Feedback on the first round climate mitigation activities

22/2/2019
Feedback on the usability of the taxonomy

19/2/2019
BVI’s response to the Consultation Paper “On integrating sustainability risks and factors in MiFID II” published by ESMA on 19 December 2018 (ESMA35-43-1210)

19/2/2019
BVI’s response to the ESMA consultation paper on integrating sustainability risks and factors in the UCITS Directive and AIFMD (ESMA34-45-569)

14/2/2019
BVI position paper on the ESMA consultation paper draft guidelines on the reporting to competent authorities under article 37 of the MMF Regulation (ESMA34-49-144)

30/1/2019
Consultation Paper on Technical Advice on the integration of sustainability risks and factors in the delegated acts  under Solvency II and IDD

31/1/2019
BVI position on IOSCO Report: Leverage

25/1/2019
EU Ecolabel for Financial Products: 1st Stakeholder Questionnaire on the product scope and criteria definition

28/12/2018

BVI position on Draft implementing technical standards amending Implementing Regulation
(EU) 2016/1800 on the allocation of credit assessment institutions to an objective scale of credit
quality steps in accordance with Directive 2009/138/EC

13/12/2018
Facilitation of cross-border fund distribution; BVI’s comments in view of the upcoming trialogue

6/12/2018
BVI’s response to the Joint Consultation Paper concerning amendments to the PRIIPs KID from 8 November 2018 (JC 2018 60)

30/11/2018
BVI’s position paper on ESMA’s consultation paper "Draft guidelines on stress test scenarios under the MMF Regulation"

17/10/2018
BVI’s submission to the public consultation on “proposed revisions to prohibitions and restrictions on proprietary trading and certain interests in, and relationships with, hedge funds and private equity funds”

27/9/2018
BVI’s response to the FCA Call for Input “PRIIPs Regulation – initial experiences with the new
requirements”

24/9/2018
Adaptation of the calculation methodology for transaction costs under the PRIIPs Regulation: suggestions by BVI and EFAMA

24/9/2018
BVI position paper on the consultation paper “EBA draft guidelines on outsourcing arrangements”

24/9/2018
BVI position paper on drafted Guidelines on the submission of periodic information to ESMA by Credit Rating Agencies

20/9/2018
“FSB Thematic Peer Review on Implementation of the LEI”; BVI reply

3/9/2018
BVI / IA position on the application of the tick size regime on systematic internalizers

23/8/2018
European Commission’s Sustainable Finance Initiative – Regulation on disclosures relating to sustainable investments and risks

23/8/2018
European Commission’s Sustainable Finance Initiative – Establishment of a framework to facilitate sustainable investment

22/8/2018
European Commission’s Sustainable Finance Initiative – Establishment of a framework to facilitate sustainable investment: Proposal to amend Regulation (EU) 2016/1011 on low carbon benchmarks and positive carbon impact benchmarks

21/8/2018
Common Ownership: Impact of institutional investors’ minority shareholding on competition in an industry sector

13/7/2018
BVI’s position on the first public consultation by the working group on euro risk-free rates on the assessment of candidate euro risk-free rates 

9/7/2018
BVI feedback on the Proposal for a Directive amending Directive 2017/1132 as regards the use of digital tools and processes in company law

26/6/2018
BVI position on the European Commission´s proposal for a Directive on representative actions for the protection of the collective interests of consumers, and repealing Directive 2009/22/EC as part of the New Deal for Consumers

26/6/2018
BVI’s opinion on the possible revision of the wholesale third-country regime under MiFIR

21/6/2018
European Commission’s Sustainable Finance Initiative – MiFID II suitability requirements BVI’s view

9/5/2018
BVI’s position on Commission‘s proposal on cross-border fund distribution

9/5/2018
BVI’s position on Commission‘s proposal regarding implementing measures of the revised Shareholders’ Rights Directive

8/5/2018
The exemption from scope of the PRIIPs framework for retail investment funds should be extended by another two years until 31 December 2021

14/3/2018
Public consultation on fitness check on supervisory reporting

8/3/2018
Summary of BVI’s position paper on a new prudential framework for MiFID investment firms

22/1/2018
Fund Fees: Money for Value

22/1/2018
Public consultation on institutional investors and asset managers' duties regarding sustainability

12/1/2018
BVI`s position on the first ECB public consultation on developing an euro unsecured overnight interest rate

11/12/2017

BVI’s view on responsible investment

24/11/2017
BVI`s position on the LEI ROC Consultation Document on Funds Relationship in the Global LEI System

22/11/2017
BVI’s position on the Commission’s proposal for reforming the European System of Financial Supervision

17/11/2017
BVI’s response to the FSB consultation document on Governance arrangements for the unique
product identifier (UPI)

13/10/2017
BVI’s response to the ESMA Consultation on Guidelines on certain aspects of the MiFID II suitability requirements (ESMA35-43-748)

28/9/2017
ESMA Consultation on format and content of the prospectus (ESMA31-62-532)

18/9/2017
BVI position on IOSCO’s consultation on CIS liquidity risk management

5/9/2017
Questionnaire by the High Level Expert Group on sustainable finance interim report

25/8/2017
BVI position paper on a new prudential framework for MiFID investment firms

17/8/2017
BVI’s comments on the draft Delegated Regulation on conduct of business rules for the distribution of insurance-based investment products

7/8/2017
BVI’s response to ESMA’s consultation paper on draft technical advice, implementing technical standards and guidelines under the MMF Regulation (ESMA34-49-82)

31/7/2017
BVI’s response to the ESMA consultation paper on the trading obligation for derivatives under MiFIR (ESMA70-156-71)

12/7/2017
BVI position on Euro clearing by systemically important third country CCPs

16/5/2017
Public consultation on the operations of the European Supervisory Authorities

19/4/2017
BVI’s response to the European Commission’s Inception Impact Assessment on the Review of the appropriate prudential treatment for investment firms

23/3/2017
BVI’s response to the ESA’s consultation on EOS PRIIPs

17/3/2017
European Commission public consultation on the capital markets union mid-term review 2017

2/2/2017
BVI’s response to the EBA discussion paper on new prudential regime for MiFID firms

27/1/2017
BVI’s response to the Consultation Paper “Joint ESMA and EBA Guidelines on the assessment of the suitability of members of the management body and key function holders under Directive 2013/36/EU and Directive 2014/65/EU”

1/5/2017
BVI position on ESMA’s consultation paper (CP) regarding draft guidelines on MiFID II product governance requirements

4/12/2015

Study of the remuneration provisions of the CRD IV; Questionnaires for Asset Management Companies and Banks/Firms

16/11/2015
BVI`s position on the consultation document on including data on branches in the Global LEI System

23/10/2015
BVI Position on draft guidelines on sound remuneration policies under the UCITS Directive and AIFMD (2015/ESMA/1172)

14/10/2015
BVI’s response to the Consultation Paper “Draft regulatory technical standards under the ELTIF Regulation” (ESMA/2015/1239)

9/10/2015
2015 10 09_FISMA CRAs Competition Survey INVESTORS_BVI comments

30/9/2015
BVI`s response to the CPMI/IOSCO Consultative Report on Harmonisation of the UniqueTransaction Identifier

31/8/2015
Shareholder Rights Directive review (“SRD II”) – BVI’s comments regarding the upcoming trialogue

17/8/2015
BVI’s comments to the Technical Discussion Paper “Risk, Performance Scenarios and Cost Disclosures in Key Information Documents for Packaged Retail and Insurance-based Investment Products (PRIIPs)”

13/8/2015
BVI`s response to the Consultation on Regulation (EU) NO 648/2012 on OTC Derivatives, Central
Counterparties and Trade Repositories

4/8/2015
Second Questionnaire on Other CRA Products

24/7/2015
BVI’s comments in relation to the Peer Review on implementation of the FSB policy framework for shadow banking entities

10/7/2015
BVI position on the ESAs Second Consultation Paper on Draft Regulatory Technical Standards on risk-mitigation techniques for OTC-derivative contracts not cleared by a CCP under Article 11(15) of Regulation (EU) No 648/2012

8/7/2015
ESMA Consultation Paper on Draft guidelines for the assessment of knowledge and competence (ESMA/2015/753)

19/6/2015
BVI’s responses to the “Questionnaire on barriers to free movement of capital“ prepared by the EU Commission

19/6/2015
BVI’s response to the Consultation on Draft EBA Guidelines on limits on exposures to shadow banking entities which carry out banking activities outside a regulated framework under Article 395 para. 2 Regulation (EU) No. 575/2013 (EBA/CP/2015/06)

15/6/2015
ESMA Consultation Paper on draft guidelines on complex debt instruments and structured deposits (ESMA/2015/610)

3/6/2015
BVI Position on draft guidelines on sound remuneration policies under Article 74(3) and 75(2) of Directive 2013/36/EU and disclosures under Article 450 of Regulation (EU) No 575/2013

29/5/2015
BVI’s response to the 2nd Consultative Document by the FSB and IOSCO on Assessment Methodologies for Identifying Non-Bank Non-Insurer Global Systematically Important Financial Institutions

13/5/2015
BVI’s-response to the EU Green Paper “Building a Capital Markets Union”

13/5/2015
BVI´s comments on the consultation document for a review of the prospectus directive

31/3/2015
BVI comments regarding ESMA’s call for evidence Competition, choice and conflict of interest in the credit rating industry

27/3/2015
BVI’s position on the Consultative Document of the Basel Committee on Banking Supervision: Revision to the Standardised Approach for credit risk

25/3/2015
BVI’s response to ESMA’s Discussion Paper on share classes of UCITS (ESMA/2014/1577)

20/3/2015
BVI position paper on Joint Committee Consultation Paper on guidelines for cross-selling practices

5/3/2015
Publication duties for portfolio managers placing orders with other entities for execution – addendum to BVI’s position paper dated 11 February 2015

4/3/2015
BVI’s position on the Consultative document on Developments in credit risk management across sectors: current practices and recommendations

27/2/2015
BVI comments regarding ESAs’ discussion paper The Use of Credit Ratings by Financial Intermediaries Article 5(a) of the CRA Regulation (JC/DP/2014/01)

2/3/2015
BVI position on ESMA Consultation Paper on MiFID II/MiFIR (ESMA/2014/1570)

17/2/2015
BVI’s response to the Discussion Paper “Key Information Documents for Packaged Retail and Insurance-based Investment Products (PRIIPs)” published by the ESAs on 17 November 2014 (JC/DP/2014/02)

13/2/2015
BVI`s position on the ESMA Consultation Paper on the Review of the technical standards on reporting under Article 9 of EMIR (ESMA/2014/1352)

12/2/2015
BVI position on the FSB Consultative Document on Standards and Processes for Global Securities Financing Data Collection and Aggregation

11/2/2015
BVI’s comments regarding ESMA’s technical advice to the Commission on investor protection issues of MiFID II

29/01/2015
BVI’s comments regarding the upcoming trilogue on IMD II

08/01/2015
BVI’s response to ESMA’s call for evidence on AIFMD passport and third country AIFMs (ESMA/2014/1340)