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In its response
AMIC, the buy-side voice of ICMA, highlighted several challenges with
the implementation measures proposed by the three European authorities,
including both firm and product disclosure requirements. For instance,
the proposed quantitative disclosure of asset management companies' ESG
footprints would not only be of little relevance to investors who invest
in products, but it will give them an inaccurate picture of the
principal adverse impacts of assets under management (AUM), as many
asset classes (sovereign bonds, green bonds, money markets and cash
equivalents, currency, some commodities) cannot be evaluated against the
proposed KPIs and given that this approach does not consider the
materiality concept.