ALFI's comments on the IOSCO public consultation on principles for the regulation on ETFs

09 July 2012

ALFI welcomes IOSCO's initiative to consult on principles for the regulation of Exchange Traded Funds. ALFI would like to highlight that in the EU, a majority of ETFs are UCITS products that are already subject to high level of rules in terms of investor protection and disclosure.

ALFI fails to understand the reasons for which IOSCO believes there is a need to discuss marketing and sales standards specifically in relation to ETFs (Chapter 3 – Principles related to marketing and sales of ETF shares). In ALFI's opinion, provisions for marketing and sale of ETFs should be part of a global distribution framework for financial products in general and not differentiated from the requirements applicable to other CIS and other types of competing financial products.

ALFI would like to highlight that most of the topics raised in this consultation do not just concern ETF’s but also other CIS as well as other financial products sold to the public (ETPs, structured notes, insurance products,…). ALFI would therefore encourage IOSCO to enlarge the scope of this proposal to include all financial products available to the public and not just ETF’s.

Full comment paper

© ALFI - Association of the Luxembourg Fund Industry