ALFI is of the view that in its initiative, EBA (leading the RTS drafting on behalf of ESAs) is taking a banking stance.
Its proposal
looks very much inspired from prudential banking regulation, with a
strong governance around the use of models like in the CRR (Regulation
EU 575/2013) that applies to credit institutions, and recently amended
in light of the Basel III reform. Such views do not take into account
the profile of investment funds.
Moreover, the introduction of a specific governance on IMMV
represents an unnecessary burden for asset managers using an already
approved model (ISDA SIMM): approval by the NCA, monitoring,
backtesting.
View the ALFI response.
ALFI
© ALFI - Association of the Luxembourg Fund Industry
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