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AMIC welcomes many of the very positive aspects of the proposals. ICMA and AMIC are strong supporters of Capital Markets Union (CMU) and we welcome proposals which will help to deliver better functioning capital markets for investors, including in the areas of: (1) enhanced supervisory convergence; (2) inclusion of ESG factors; (3) cost-benefit analyses for guidance and recommendations; (4) improved third country equivalence; and (5) role for ESMA in data collection.
Nevertheless, AMIC also has some significant concern with several elements of the texts. These proposals should be revisited if this framework is to be successful in increasing supervisory convergence and addressing the challenge of the UK leaving the EU. Our significant concerns, which we will outline in greater detail in our response, are in the areas of: (1) direct supervision of funds; (2) ESMA opinions on delegation arrangements; (3) funding arrangements; (4) consultations on Q&As; and (5) organisation of the ESRB.