The document sets out 14 final policy recommendations to address four “alleged” structural vulnerabilities from asset management activities that could potentially present financial stability risks:
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Liquidity mismatch between fund investments and redemption terms and conditions for open-ended fund units;
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Leverage within investment funds;
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Operational risks and challenges for asset managers in stressed conditions, particularly with regard to the transfer of client mandates;
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Securities lending activities and related indemnification programmes offered by certain asset managers.
Additionally, below are some general remarks on issues raised in the FSB Report:
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Despite the fact that some of the speculative narrative around potential risks stemming from liquidity mismatches in open-end funds has been retained in the final report, we welcome that fact that several of the risk-mitigants highlighted by EFAMA in our responses have been acknowledged by the FSB in its final Report.
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EFAMA views it as positive that the first nine liquidity management-related recommendations call on IOSCO to review/enhance its existing guidance by end-2017, as well as develop a set of harmonised data points for authorities to monitor the build-up to liquidity risks in funds.
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Also positive is that certain recommendations introduce sufficient flexibility for national authorities to take action only "where appropriate" or "where relevant", including the possible consideration of system-wide stress-testing judging on the relative systemic importance of actors in each jurisdiction and once better data become available;
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Regarding leverage, EFAMA welcomes that the FSB recommendations on data on leverage in funds be aggregated and made consistent across the global jurisdictions. We support the work to be undertaken by IOSCO in collaboration with national authorities by the end of 2018.
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As to operational risks, EFAMA believes that these remain overstated. In this regard, EFAMA stresses that the current EU regulatory framework as well as industry best practices largely already address the FSB’s concerns.
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Finally, EFAMA believes that the potential risks with regard to securities lending as a potential source of systemic risks, via the indemnification of clients where asset managers are also agent-lenders, are overstated.
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© EFAMA - European Fund and Asset Management Association
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