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Having the new prudential regime in place prior to the end of the European Parliament’s mandate is even more important given the recent agreement reached in CRD/CRR which currently covers part of the investment firms in Europe.
A timely agreement also on IFD/IFR will spare investment firms from the burden and legal uncertainty of applying first and for a short period of time the new bank legislation package and after that the new regime tailored for investment firms which entails a different approach.
At the same time, it is important for EU policy makers to keep in mind the need for compatibility between a number of rules foreseen in IFD/IFR and the existing EU legislation that applies to investment firms.
The disclosure requirements for investment policy, where the Shareholders Rights Directive and the Transparency Directive already apply, the country-by-country reporting, where the recently adopted CRD/CRR foresee a similar regime and the disclosures on sustainability risks are a few examples showcasing the need for a compatible approach in terms of legal clarity and consistency.
EFAMA will analyse further the details of the political agreement as well as any additional input stemming from the technical trilogues in order to assess whether the new regime will address appropriately and efficiently the multitude of very different business models it will apply to.
With respect to MiFID-licensed asset management companies offering individual portfolio management and investment advice a proportionate approach is of paramount importance as they are not authorised to hold client money or securities belonging to clients, nor to deal on their own account.