24 October 2017

ALFI（ルクセンブルク・ファンド業協会）、欧州委員会による不良債権のセカンダリー市場の発展に関する市中協議へのコメントを公表

The Association of the Luxembourg Fund Industry (ALFI) thanks the European Commission for the opportunity to participate in this consultation on nonperforming loans (NPLs). ALFI understands the consultation’s main focus, in accordance with the action plan published by the Council of the European Union on 11 July 2017, is to receive information on the current state of secondary markets for NPLs in the European Union.

Therefore, the questions raised in the questionnaire are more targeted to banks with the aim to identify impediments to the transfer of NPLs from banks to non-bank investors.

However, when creating a new framework for NPLs, ALFI thinks it is also important to bear in mind the role played by loan funds. In the context of a low interest rate environment and scarcity of bank credit, non-bank entities such as investment funds have become increasingly involved in capital markets and credit intermediation. 

As recently confirmed by IOSCO, loan funds in the EU are allowed in almost all Member States and are predominantly located in Luxembourg and the United Kingdom. By providing credit to economic actors, loan funds play an important role in achieving economic growth which complies with the goal of the European Commission’s Capital Markets Union and Investment Plan for Europe.

It is worth noting in this context that in Luxembourg, loan funds were already set up long before the financial crisis of 2008 which allows the Luxembourg fund industry to rely on expert knowledge and experience in this field.

ALFI‘s main comment aims at preserving existing flexibility for loan funds within the framework of the Alternative Investment Fund Managers Directive (AIFMD), but also with regard to the European Venture Capital Funds (EuVECA), European Social Entrepreneurship Funds (EuSEF) and European LongTerm Investment Funds (ELTIF) Regulations.

Full response

© ALFI - Association of the Luxembourg Fund Industry