AMIC Responses

4 September 2023
AMIC response to IOSCO consultation AD LMT

4 September 2023
AMIC response to FSB consultation on liquidity mismatch in OEF

24 August 2023
AMIC response to ESMA's consultation on the draft regulatory technical standards under the revised ELTIF regulation

3 July 2023
ICMA response to the ESAs’ joint consultation on the review of the SFDR Delegated Regulation

21 June 2023
ICMA response to HMT consultation on ESG ratings providers

20 February 2023
ICMA response to ESMA’s Guidelines on funds’ names using ESG or sustainability-related terms

AMIC response to the ESMA consultation paper 'Guidelines on certain aspects of the MiFID II suitability requirements'

27 April 2022  AMIC submitted its response to the ESMA consultation paper on the ‘Guidelines on certain aspects of the MiFID II suitability requirements’. In its response, AMIC highlighted the implementation challenges of the 2 August application date from product manufacturer, distributor and end-investor perspectives; and made specific suggestions on the proposed draft guidelines to help the clients assessment process and align the final guidelines to the Delegated Act. Most critically, AMIC recommended a no action letter from the ESAs advising NCAs to not prioritize supervisory action towards implementing sustainability preferences in the MiFID II suitability assessment as of 2 August 2022. This forbearance period would allow firms to implement the final guidelines avoiding the burden and risks arising from double implementation; as well as wider availability of products to offer to clients following their suitability assessment as the necessary (corporate related) data should become available and more reliable in 2025 the earliest. members have launched ELTIFs (9 in total).

ICMA response to the SEBI consultation paper on introducing disclosure norms for ESG Mutual Fund schemes

16 November 2021 ICMA has responded to the SEBI consultation paper on introducing disclosure norms for ESG Mutual Fund schemes.

AMIC response to EC consultation to review the EU securitisation regulation (SECR)

17 September 2021 AMIC has responded to the EC consultation to review the EU securitisation regulation (SECR). The response highlights that the low level of securitisation issuances since the entry into application of the SECR is mainly due to the accommodative monetary policies of central banks, but that there is still merit in introducing amendments to the SECR and related prudential rules measures to grow both the investor and the issuer base and contribute to the CMU objectives.

AMIC response to the UK FCA CP21/17: Enhancing climate-related disclosures by asset managers, life insurers and FCA-regulated pension providers

10 September 2021 AMIC has submitted its response to the UK FCA CP 21/17: Enhancing climate-related disclosures by asset managers, life insurers and FCA regulated pension providers. AMIC welcomed the FCA’s proposals and noted that that the sequencing of the disclosure requirements should be first on the issuer side at international level (upcoming IFRS standard), followed by the buyside, and that in the meantime the proposed approach is applied on a “as far as they are able” approach, with accepted use of proxies and estimated data.

AMIC response to IOSCO’s consultation on Sustainability-Related Practices, Policies, Procedures and Disclosure in Asset Management

13 August 2021 AMIC has submitted its comments on IOSCO’s consultation on Sustainability-Related Practices, Policies, Procedures and Disclosure in Asset Management. AMIC expressed its support for IOSCO’s recommendations and highlighted the key priority areas in needing to address the risk of market fragmentation, mitigating data gap challenges and ensuring global alignment across jurisdictions.

ICMA response to ESMA consultation on potential reforms of the EU Money Market Funds Regulation (MMFR)

30 June 2021 ICMA has today responded to ESMA's consultation on potential reforms of the EU Money Market Funds Regulation (MMFR). Our Asset Management and Investors Council (AMIC), the buy-side voice of ICMA, mainly drafted this response. It also draws on the work done by ICMA’s Commercial Paper Committee and its upcoming white paper on the European Commercial Paper and Certificates of Deposit Market.

AMIC responds to FCA consultation on UK MiFID research and best execution

23 June 2021 ICMA’s Asset Management and Investors Council has responded to the FCA consultation paper CP21/9 on UK MiFID research and best execution. In its response, ICMA welcomed an exemption for FICC research from unbundling rules as well as the proposal to remove the RTS 27 and RTS 28 best execution reports.

AMIC publishes discussion paper on ESG KPIs for Auto-loans/leases ABS

17 May 2021 In the context of growing demands from asset owners to evaluate their ESG footprint and greater regulatory scrutiny (such as SFDR), ICMA’s Asset Management and Investors Council has set up an ad hoc working group to discuss ESG transparency of Asset-Backed Securities.

As a first step the working group (composed of buy-side firms) issued a statement laying down current challenges for this specific asset class and the buy-side. This subsequent discussion paper issued today focuses on ESG KPIs for auto-loans/leases ABS. Next steps are to identify key performance indicators for two other sub asset classes (RMBS and CLOs). The working group will engage with other market participants and regulators to promote the usage of identified KPIs.

AMIC response to ESAs consultation on taxonomy disclosure for financial products

12 May 2021 AMIC has submitted its response to the ESAs consultation on taxonomy disclosure for financial products. The EU Taxonomy regulation requires certain financial products with environmental characteristics/objectives (as defined under the EU Sustainable Finance Disclosure Regulation (SFDR)) to report how their underlying investments align with the recently adopted EU criteria for sustainable activities. The response invites the ESAs and the EC to allow for sufficient implementation time, to refine the list of eligible assets to be factored in the Taxonomy KPI, and to simplify information to be disclosed to end-investors.

AMIC and EFAMA issue a joint response to the IOSCO consultation on fund liquidity management by open-ended funds

21 April 2021 AMIC and EFAMA have submitted a joint response to the IOSCO consultation on fund liquidity management by open-ended funds.

The response highlights how industry practices and existing regulatory provisions in Europe are well aligned with the Liquidity Risk Management (LRM) recommendations issued by IOSCO in 2018.

AMIC and EFAMA also acknowledge the positive impact of the LRM recommendations, as they have incentivised national supervisors to encourage and facilitate the use of LMTs, which are now available in most European jurisdictions and in all main fund domicile centres, covering almost all AuM managed by UCITS and AIFs.

The response notes that, in the context of the COVID-19 market downturn in March/April 2020, liquidity risk was well management by investment funds domiciled in Europe and refer to an ESMA report which concluded that (1) out of the 174 AIFs studied, none used substantial leverage nor had to suspend redemption and (2) out of the 459 UCITS fund studied, only 6 UCITS funds suspended temporarily (up to 13 days).

This shows that fund liquidity risk management is overall sound in European funds and that existing EU rules - including those implementing IOSCO LRM - are sufficient. However, AMIC and EFAMA reiterate the need to facilitate the access to information related to shares/units held by the different categories of underlying investors to better appraise liability risks.

AMIC statement on ESG transparency of Asset-Backed Securities

18 March 2021 AMIC has set up an ad hoc working group to discuss ESG transparency of Asset-Backed Securities. As a first step the working group has issued a statement laying down current challenges for this specific asset class and the buy-side. Next steps are to identify key performance indicators for three sub asset classes (auto-loans, RMBS and CLOs) which could then be embraced by market participants and/or regulators. ABS investors and originators who would like to join these conversations can contact the AMIC secretariat.

AMIC responds to EC consultation on the review of the alternative investment fund managers directive (AIFMD)

29 January 2021 AMIC has responded to the EC's consultation on the review of the Alternative Investment Fund Managers Directive (AIFMD). AMIC argues in favour of legislative stability given (1) the findings of the recent COVID-19 crisis (no suspension for the 174 AIFs scrutinised by ESMA in its report to ESRB) and (2) the recent complementary measures already adopted at EU level (eg. Liquidity Stress Testing guidelines; crossborder distribution of funds package) which are yet to be fully implemented and assessed. AMIC calls on the EC to focus on vehicles which, with changes, could foster growth in European capital markets (eg the ELTIF ongoing review consultation) rather than those which have been successful in ensuring EU’s competitiveness and attractiveness.

AMIC responds to EC consultation on the review of the European long-term investment funds (ELTIF) regulatory framework

28 January 2021 AMIC has submitted its response to the European Commission's consultation on the review of the European Long-Term Investment Funds (ELTIFs) Regulation. AMIC welcomes this review and encourages the EU to have a bold approach given that no more than 28 ELTIFs were launched since 2015. Among AMIC members, who oversee assets classes that could be eligible to ELTIFs, only three members have launched ELTIFs (9 in total).

AMIC responds to third EC consultation on the EU Ecolabel for financial products

11 December 2020 AMIC has today published its response to the third EC consultation on the EU Ecolabel for financial products. While AMIC continues to support the idea of an EU sustainable label for retail investments funds, it also warns that, at best, only a residual portion of the greenest of sustainable funds will be able to meet the proposed requirements. Based on studies conducted by the EC itself and members of the UNPRI, AMIC therefore recommends to recalibrate the green thresholds, strictly align the EU Ecolabel on the EU Taxonomy framework, and review requirements for bond funds as they are not in line with current market practices and need to include more broadly bonds aligned with the Green Bond Principles.

AMIC responds to ESMA's public consultation on Article 8 of the Taxonomy regulation

4 December 2020 AMIC submitted its response to ESMA's public consultation on Article 8 of the Taxonomy regulation which requires companies in the scope of NFRD (i.e. large listed companies ) to disclose their level of taxonomy alignment (turnover, capex, opex) in their non-financial statement. This consultation focuses on non-financial issuers and asset managers as EBA and EIOPA are looking at banks, insurers and pension funds in separate consultations. Regarding asset managers, ICMA’s response recommends a look-through approach focusing on investment funds with sustainability claims, the consideration of all green bonds (including the ones aligned with the Green Bond Principles) and other relevant assets which can be assessed against the taxonomy, and the optional use of proxies for non-listed issuers.

AMIC responds to ESA's survey on templates for Environmental and/or Social financial products under SFDR

16 October 2020 AMIC submitted its response to the ESAs' survey on templates for Environmental and/or Social financial products under SFDR.

AMIC publishes position paper on ESMA's letter on AIFMD review

12 October 2020 AMIC published a series of first views on the review of AIFMD following ESMA's letter and ahead of the upcoming EC consultation. AMIC argues that the current framework, which was continuously enhanced over the years has proven to be fit for purpose in light of the crisis and that re-writing AIFMD and the UCITS directive on key aspects (such as delegation, leverage/liquidity, reporting) as suggested by ESMA would be a major distraction for policy makers, supervisors and asset managers at a time when collective energy should be devoted to the post-COVID 19 recovery, the Sustainable Finance Action Plan and the Capital Markets Union. AMIC believes a lot of the points raised in ESMA's letter can be dealt with by the European authority and NCAs by making use of their existing and recently reinforced powers (i.e. Guidelines, Q&As, Common Supervisory Action) or via targeted level 2 measures and calls the EC, to focus on vehicles which, with changes, could foster growth in European capital markets (e.g. ELTIF) rather than those which have been successful in ensuring EU’s competitiveness and attractiveness.

AMIC responds to EC consultation on investment research

11 September 2020 AMIC submitted its response to the EC consultation on investment research. The response explains that partially reviewing unbundling rules will not contribute to reviving SME research to a meaningful extent as a majority of members would practically not be able to make use of the options proposed by the EC. AMIC therefore recommends that the EC consider other policy options to support SME research and funding in the context of post-COVID recovery (free-trial and issuer-sponsored research).

AMIC responds to ESAs' consultation on the Sustainable Finance Disclosure Regulation

1 September 2020 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. In light of the expected delay in adopting the implementation measures and the scale of the issues to be resolved, AMIC once again urges the EC and the ESAs to postpone the application date of SFDR.

AMIC responds to ESMA consultation on guidelines for NCAs when they consider potential financial stability risk associated with leverage in AIFs

1 September 2020 In its response AMIC, the buy-side voice of ICMA, recommends focusing on funds with substantial leverage as a first screening phase and  conducting an analysis of  relevant parameters related to a given fund. AMIC strongly recommends analysing funds individually and not in groups: similar AIFs may have leverage tolerance according to clients' profiles, dealing cycles and recent performances. Finally the response suggests that the implementation of these guidelines should rely on data already reported under LST guidelines, AIFMD, EMIR, SFTR and should not lead to further reporting by asset managers.

AMIC submits response to the EC consultations on the integration of sustainability risks in UCITS, AIFMD and MiFID

6 July 2020 AMIC submitted its response to the EC consultations on the integration of sustainability risks in UCITS, AIFMD and MiFID. In its reponse AMIC fully supports the integration of sustainability risks among other risks to be considered by fund managers and investors, which can indeed affect the return of assets and portfolios. It also recalls the urgent need to review NFRD in order to provide fund managers with audited and reliable data from issuers and argues that until this is completed the assessment of sustainability risks to be presented to end-clients should be allowed on qualitative basis. Finally, the response urges the EC not to limit the scope of sustainable products available to investors via distribution rules and recall the need for a certain degree of flexibility to meet different needs and preferences from investors (notably from a risk management perspective).

ICMA responds to EC consultation on the Review of the Non-Financial Reporting Directive (NFRD).

11 June 2020 ICMA today submitted its response to the NFRD review consultation. Both ICMA's Corporate Issuer Forum and the Asset Management and Investors Council support the review, which provides the opportunity to achieve a greater level of standardisation of ESG disclosures, a perequisite to deliver on the EU sustainable finance action plan.

AMIC responds to EC consultation on the EU Ecolabel for financial products

17 April 2020 While AMIC supports the idea of an EU quality stamp for ESG retail investments funds it also warns that some important changes are required to ensure the success of this new label. AMIC recommends in particular broadening the list of eligible assets for diversification purposes but also to further support companies transitioning to a lower-carbon business model.

View the response.

AMIC responds to EC consultation on improving resilience of financial services against cyberattacks

19 March 2020 Based on the ESA’s opinion issued in April 2019, the EC is considering introducing changes to the sectorial legislation (e.g. UCITS, AIFMD) to enhance cyber-resilience. In our response we argue that the regulatory framework already allows us to address cyber-risk in the asset management industry.

This has given supervisors the possibility to thoroughly test the cyber-resilience of asset managers. There is therefore no legal impediment and no need to reopen sectorial rules to enhance cyber-resilience in the asset managment sector.

AMIC responds to ESAs consultation on PRIIPs RTS

On 13 January 2020 ICMA’s Asset Management and Investors Council (AMIC) submitted a response to the ESAs' consultation on PRIIPs RTS. (See distinct primary market aspects on ICMA’s primary market response)

AMIC responds to ESMA’s consultation on possible short-term pressure from the financial sector on corporations

On 29 July 2019 ICMA’s Asset Management and Investors Council (AMIC) submitted a response to ESMA’s consultation on possible short-term pressure from the financial sector on corporations. AMIC refutes the idea that short-termism is a prevalent bias of asset managers and calls for a regulatory framework which can further foster capital allocation towards sustainable and long-term assets.

AMIC responds to ESMA consultation on liquidity stress testing guidelines

On 28 March 2019 ICMA’s Asset Management and Investors Council (AMIC) submitted a response to ESMA’s consultation on liquidity stress testing in UCITS and AIFs. AMIC is supportive of ESMA’s overall approach. However, AMIC cautions that some implementation time is necessary for firms to comply with the requirements. AMIC proposes 18 months implementation time for firms. AMIC also cautions against the use of the bid-ask spread as a liquidity measure for securities and warns that a lack of data on underlying investors make redemption stress testing difficult for asset managers.

AMIC responds to ESMA consultation on integrating sustainability risks and factors in the UCITS Directive and AIFMD

On 19 February 2019 AMIC published its response to a consultation by the European Securities and Markets Authority (ESMA) on integrating sustainability risks and factors in the UCITS Directive and AIFMD. AMIC agrees overall with ESMA’s approach to the mandate given by the European Commission to provide technical advice to amend Level 2 legislation for the UCITS Directive and AIFMD. This high-level, principles-based approach is the right framework for UCITS firms and AIFMs to integrate sustainability risks in their investment processes. However, AMIC has suggested some clarifications for the technical advice, including (1) limiting the coverage to “risks” and not “factors, (2) strengthening the materiality of sustainability risks and (3) preferring “sustainability” to “ESG” risks for consistency purposes.

AMIC responds to IOSCO consultation on leverage in investment funds

On 1 February 2019 AMIC published a response to a consultation report by the International Organization of Securities Commissions (IOSCO) on leverage in investment funds. In its response, AMIC welcomes the focus by IOSCO on each fund level on the potentially risky activities of asset managers as compared to an approach at management company level. Furthermore, AMIC agrees with IOSCO’s proposed two-step approach to measuring risk associated with leverage. With regard to the first step, AMIC recommends that the gross notional exposure (GNE) figure is combined with the net notional exposure (NNE) figure to filter potentially risky funds. AMIC views the second step as a framework for a more detailed risk-based analysis of risk in each jurisdiction, recognising that leverage as a concept is not synonymous with risk.

2018

16 May 2028
AMIC issued a position paper on the on-going review of the European Systemic Risk Board (ESRB). In light of the recent Recommendation on liquidity and leverage risks in investment funds (ESRB/2017/6), we believe that ESRB’s governance could be improved. AMIC believes that the lack of public consultation, the intrusion by macro-risk supervision into the field of micro-regulation, and the unbalanced composition of the board of the ESRB justifies that the ESRB review includes an improvement of the functioning and composition of the ESRB. AMIC lays out two targeted changes to the ESRB review proposal to balance the composition of the ESRB to ensure greater representation from securities markets and to ensure consultation with industry takes place where legislative change is recommended.

28 February 2018
AMIC responded to a consultation by the UK Financial Reporting Council (FRC) on the review of the UK Corporate Governance Code and on the UK Stewardship Code. The AMIC response calls for an enhanced role for bond holders in corporate engagement with stakeholders but recommends that the comply and explain approach is retained as a flexible way for companies and investors to adhere to the Code. AMIC looks forward to continued engagement with the FRC, in particular when a more thorough review of the Stewardship Code is launched later this year.

23 January 2018
AMIC published its response to the publication of the proposals to review the European Supervisory Authorities (ESAs) and the European Systemic Risk Board (ESRB).

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.

22 January 2018
AMIC issued a brief statement in response to a consultation by the European Commission on investor duties and asset managers’ duties regarding sustainability. The AMIC statement is limited to the potential legislative consequences of the initiative to clarify investor duties, subject to specific recommendations in the Final Report of the High-Level Expert Group on Sustainable Finance.

2017

18 September 2017
AMIC responded to IOSCO’s consultations on (1) CIS Liquidity Risk Management Recommendations and (2) Report on Open-ended Fund Liquidity and Risk Management – Good Practices and Issues for Consideration.

AMIC broadly agrees with the suggested amendments to IOSCO’s 2013 liquidity risk management recommendations. However, AMIC suggests some amendments to the recommendations to bring them in line with current market practice. Furthermore, AMIC counsels caution on stress tests, which can be misleading particularly on a systemic level. AMIC also welcomes the report on best practices on fund liquidity risk management, which helpfully references AMIC’s joint report with EFAMA on liquidity risk management.

The responses can be found here:
(1) AMIC response to IOSCO Consultation on CIS Liquidity Risk Management Recommendations
(2) AMIC response to IOSCO Consultation Report on Open-ended Fund Liquidity and Risk Management – Good Practices and Issues for Consideration

15 August 2017
ICMA's AMIC has submitted a response to the Central Bank of Ireland’s Discussion Paper on Exchange Traded Funds (ETFs). AMIC has long taken an interest in the development of ETFs. AMIC has long taken an interest in the development of ETFs. In 2011 AMIC published a short general paper on ETFs with a description of different types of ETFs, the state of the ETF market, assessments of market trends in ETF development and usage, the future development of the ETF market and the value of the ETF brand. More recently, AMIC’s interest in ETFs is limited to their relevance to the debate on systemic risk. We have already been active in the global debate on the possible systemic risk related to asset managers.
The AMIC response on ETFs addresses certain topics in the consultation, in particular potential systemic risks in ETFs and the impact of ETFs on corporate bond liquidity.
To view the response, click here.

2016

24 October 2016
On 24 October 2016, ICMA's AMIC submitted its response to the European Commission's consultation paper on whether the existing EU macro-prudential framework is functioning optimally. AMIC raised concern about expanding the mandate and powers of the European Systemic Risk Board (ESRB) to non-banking under the current governance framework of the ESRB. AMIC recommends much greater integration of securities markets supervisory expertise in the macro-prudential policy framework. AMIC also suggests that already reported data is better used to understand financial markets from a holistic perspective.

3 October 2016 
ICMA is conducting a consultation on the new London Term Sheet of GDP-Linked Bonds with interested members of ICMA’s Asset Management and Investors Council. Click here for more information.

21 September 2016
ICMA’s AMIC has submitted its response to the Financial Stability Board’s (FSB) consultation paper on proposed policy recommendations to address structural vulnerabilities for asset management activities.
AMIC welcomed the FSB’s focus on activities instead of designating individual companies as systemically risky. However, AMIC cautions against returning to the designation debate. AMIC also encourages the FSB to consider a wider group of market participants than simply asset managers when assessing risk and formulating policy recommendations. AMIC also notes that any effort to harmonise leverage calculation should not impact the existing methods to calculate fund leverage established through European legislation.
To view the document, click here.

7 September 2016 
The ICMA AMIC Bail-in Working Group has sent a discussion letter to the ECB. The letter highlights observations on the operation of the bail-in regime, from the buy-side point of view, and builds upon, and reflects evolutions in thinking since, a letter sent to the ECB on 31 July 2015, also on the bail-in mechanism.
To view the discussion letter, click here.

23 May 2016 
In the absence thus far of enhanced rules on mandatory pool disclosure on a Europe wide basis from the European Commission, industry led initiatives are essential to the continued good operation and standing of the covered bond market. The ICMA AMIC Covered Bond Investor Council welcomes the fact that the Harmonised Transparency Template (HTT) is to be reviewed and enhanced on a regular basis and are taking the opportunity of this review to comment on its effective implementation to date and to provide comments from members on possible features to consider as part of the review process.
The CBIC response is based on the information available on the Covered Bond Label website as well as issuers’ website. In addition, we reviewed the various responses the CBIC has written over the years regarding enhancing transparency in the covered bond market.
To view the response, click here.

18 April 2016
The International Capital Market Association’s (ICMA) Asset Management and Investors Council (AMIC) and the European Fund and Asset Management Association (EFAMA) have published today a report on the legislative requirements and market-based tools available to manage liquidity risk in investment funds in Europe. The report also offers some recommendations to further improve the general liquidity management environment.
To view the press release, click here.
To view the report, click here.
To view an executive summary, click here.

3 March 2016
Four leading European trade associations representing investors, issuers and other market participants came together to support the new framework for securitisation regulation - a robust and successful framework for simple, transparent and standardised (STS) securitisation.

6 January 2016
The ICMA AMIC Covered Bond Investors Council (CBIC) has responded to the European Commission’s consultation on Covered bonds in the European Union. The consultation was launched on 30 September 2015. The CBIC noted the underlying assumption in the economic analysis that the extreme convergence of covered bond spreads before the crisis should be the norm and that subsequent events point to a sub-optimal fragmentation of markets within the European Union. However, CBIC members argued that markets prior to 2007 had mispriced risks inherent in the securities and that a return to that condition was not necessarily a desirable outcome. Particularly in the absence of implicit state support for the banking system, different covered bonds do reflect different underlying risk characteristics and it is the job of the market to identify and price these risks appropriately.
With regard to the main question in the consultation, the two options for covered bond harmonisation, the CBIC noted that there was insufficient detail in the consultation to give a definitive view. Some CBIC members believed that voluntary convergence of national regimes would suffice, particularly if backed by measures like capital requirements referencing the best practice guidelines. Other CBIC members expressed a preference for an EU legal framework with minimum standards based on current best practice.
To view the response, click here.

2015

31 July 2015
ICMA Bail-In Working Group discussion letter to the ECB, the purpose of which is to set out views on the operation of the bail-in mechanism.

13 August 2015
AMIC response to the European Commission’s consultation on the review of the European Market Infrastructure Regulation (EMIR).

29 May 2015
AMIC’s Market Finance Working Group (formed in December 2014 to address industry concerns about regulatory focus on shadow banking) response to a second FSB/IOSCO consultation on a methodology to identify NBNI G-SIFIs.

13 May 2015
AMIC response to the Consultation Document on an EU framework for simple, transparent and standardised securitisation.

13 February 2015
AMIC joint response to the BCBS IOSCO Consultative Document on Criteria for identifying simple, transparent and comparable securitisations.

14 January 2015
AMIC joint response to the EBA’s Discussion Paper on simple standard and transparent securitisations.


2014

10 October 2014
AMIC response to the FCA Discussion Paper DP14/3 – the use of dealing commission regime

12 September 2014
ICMA Bail-in Working Group response to the questions enumerated in the Financial Policy Committee’s Review of the Leverage Ratio.

5 September 2014
AMIC response to the IOSCO consultation paper on Good Practices on Reducing Reliance on CRAs in asset management.

21 August 2014
ICMA AMIC Covered Bond Investor Council report on cover pool data disclosure, calling for further disclosure of cover pool data. To view the ICMA Transparency report click here. To view the press release, click here.

18 August 2014
ICMA CBIC response to the Consultation Paper launched by the European Securities and Markets Authority (ESMA) on 11 July 2014 on the Clearing Obligation under Regulation (EU) No 648/2012, which outlines the framework of the European Market Infrastructure Regulation (EMIR). To view the response click here.

7 April 2014
 AMIC response to the FSB/IOSCO consultation on the assessment methodologies for identifying non-bank non-insurer Global Systematically Important Financial Institutions (‘NBNI G-SIFIs’).

7 March 2014
ICMA CBIC statement welcoming the infrastructure the Covered Bond Label has put in place for further strengthening of the European covered bond market, and noting the improvement in the minimum transparency requirement. To view the statement click here

25 February 2014
AMIC response to FCA Consultation CP13/17 – the use of dealing commission rules.

31 January 2014
AMIC response to ESMA consultation paper on Revision of the provisions on diversification of collateral in ESMA’s guidelines on ETFs and other UCITS.


2013

20 December 2013
AMIC response to the Public Consultation on Best Practice Principles for Governance Research Providers

17 December 2013
ICMA CBIC statement in support of the inclusion of covered bonds as extremely high liquid assets under the Liquidity Coverage Ratio (LCR) within the new liquidity provisions for the European banking sector. To view the statement click here.

21 October 2013
ICMA CBIC letter in response to Moody’s request for comments: "Approach to Determining the Issuer Anchor Point for Covered Bonds". To view the response, click here.

7 August 2013
ICMA CBIC statement regarding covered bond rating agencies based on discussions within its membership.

14 January 2013
AMIC response to the FSB consultation papers regarding ‘strengthening oversight and regulation of shadow banking’. 


2012

18 October 2012
AMIC response to the European Commission public consultation entitled "UCITS Product Rules, Liquidity Management, Depositary, Money Market Funds, Long-Term Investments on a number of regulatory issues related to money market funds, eligible assets, the use of derivatives, and depositary passports".

28 September 2012
AMIC response to the BCBS and IOSCO consultative paper ‘Margin Requirements for non‐centrally‐cleared derivatives’

25 September 2012
AMIC response to ESMA Consultation Paper on recallability of repo and reverse repo arrangements

15 June 2012
AMIC response to the European Commission Green Paper on shadow banking.

30 March 2012
AMIC response to ESMA Consultation paper on guidelines on ETFs and other UCITS issues.

20 February 2012
The Solvency II Working Group common response to the EIOPA Consultation paper on the proposal for Quantitative Reporting Template for Financial Stability Purposes.  

20 January 2012
The Solvency II Working Group common response to EIOPA consultation paper on reporting issues.

 
2011

CBIC European transparency standards
A public consultation on the ICMA CBIC transparency template was launched on 14 April 2011, all documents are available here.
More information about the second round of consultation is available here.
The final template is available here.  

22 September 2011
AMIC response to ESMA on discussion paper on its policy orientations on guidelines for UCITS Exchange-Traded Funds and Structured UCITS.

18 November 2011
AMIC response to the Kay Review of UK Equity Markets and Long-Term Decision-Making.

22 July 2011
AMIC response to the European Commission Green Paper entitled ‘The EU corporate governance framework’.

16 May 2011
AMIC response the FSB note entitled Potential financial stability issues arising from recent trends in Exchange-Traded Funds (ETFs).

17 January 2011
AMIC statement supporting the FRC Stewardship.

17 January 2011
AMIC response to the UK Department for Business, Innovation and Skill Call for Evidence – A long‐term focus on Corporate Britain.  

14 January 2011
AMIC general comments on the AIFMD implementing measures published in CESR Call for Evidence on the AIFMD.

6 January 2011
AMIC response to the European Commission consultation on the issue of overreliance on CRAs.


2010

4 November 2010
AMIC response to IOSCO Consultation Report on Intermediary Internal Controls Associated with Price Verification of Structured Finance Products and Regulatory Approaches to Liquidity Risk Management.  
8 October 2010
AMIC response to FSA Consultation Paper – CP 10/19 – Revising the Remuneration Code.

16 August 2010
AMIC response to European Commission Green Paper – Corporate governance in financial institutions and remuneration policies.

21 January 2010
CBIC statement on the on-going usage of ‘shadow / IOI’ books.


2009

5 February 2009
AMIC response to the European Commission Services consultation paper on hedge funds.