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1. Beyond the five priority areas identified for short term action, what other areas should be prioritised?(other-areas-prioritised)
2. What further steps around the availability and standardisation of SME credit information could support a deeper market in SME and start-up finance and a wider investor base?(standardisation-sme-credit-information)
3. What support can be given to ELTIFs to encourage their take up?(support-to-eltifs)
4. Is any action by the EU needed to support the development of private placement markets other than supporting market-led efforts to agree common standards?(other-action-developing-private-placement-markets)
Comments on question 4:(comments-other-action-developing-private-placement-markets)
5. What further measures could help to increase access to funding and channelling of funds to those who need them?(further-measures-access-to-funding)
6. Should measures be taken to promote greater liquidity in corporate bond markets, such as standardisation? If so, which measures are needed and can these be achieved by the market, or is regulatory action required?(measures-to-promote-greater-liquidity)
7. Is any action by the EU needed to facilitate the development of standardised, transparent and accountable ESG (Environment, Social and Governance) investment, including green bonds, other than supporting the development of guidelines by the market?(eu-action-to-facilitate-development-esg)
Comments on question 7:(comments-eu-action-to-facilitate-development-esg)
8. Is there value in developing a common EU level accounting standard for small and medium-sized companies listed on MTFs? Should such a standard become a feature of SME Growth Markets? If so, under which conditions?(common-level-accounting-standard-for-sme)
9. Are there barriers to the development of appropriately regulated crowdfunding or peer to peer platforms including on a cross border basis? If so, how should they be addressed?(barriers-to-development-crowdfunding-or-peer-to-peer)
10. What policy measures could incentivise institutional investors to raise and invest larger amounts and in a broader range of assets, in particular long-term projects, SMEs and innovative and high growth start-ups?(investors-to-raise-and-invest-larger-amounts)
11. What steps could be taken to reduce the costs to fund managers of setting up and marketing funds across the EU? What barriers are there to funds benefiting from economies of scale?(reduce-costs-to-fund-managers)
12. Should work on the tailored treatment of infrastructure investments target certain clearly identifiable sub-classes of assets?(target-sub-classes-of-assets)
Comments on question 12:(comments-target-sub-classes-of-assets)
12.1 If so, which of these should the Commission prioritise in future reviews of the prudential rules such as CRDIV/CRR and Solvency II?(yes-target-sub-classes-of-assets)
13. Would the introduction of a standardised product, or removing the existing obstacles to cross-border access, strengthen the single market in pension provision?(introduction-of-standardised-product-removing-obstacles)
14. Would changes to the EuVECA and EuSEF Regulations make it easier for larger EU fund managers to run these types of funds?(changes-to-euveca-and-eusef)
14.1 What other changes if any should be made to increase the number of these types of fund?(other-changes)
15. How can the EU further develop private equity and venture capital as an alternative source of finance for the economy?(develop-private-equity-and-venture-capital)
15.1 In particular, what measures could boost the scale of venture capital funds and enhance the exit opportunities for venture capital investors?(measures-to-boost-scale-of-venture-capital-funds)
16. Are there impediments to increasing both bank and non-bank direct lending safely to companies that need finance?(impediments-to-increasing-bank-and-non-bank-direct-lending)
17. How can cross border retail participation in UCITS be increased?(increase-cross-border-retail-participation-in-ucits)
18. How can the ESAs further contribute to ensuring consumer and investor protection?(esa-contribution)
19. What policy measures could increase retail investment?(policy-measures)
19.1 What else could be done to empower and protect EU citizens accessing capital markets?(empower-and-protect-citizens)
20. Are there national best practices in the development of simple and transparent investment products for consumers which can be shared?(national-best-practices)
21. Are there additional actions in the field of financial services regulation that could be taken to ensure that the EU is internationally competitive and an attractive place in which to invest?(additional-actions)
22. What measures can be taken to facilitate the access of EU firms to investors and capital markets in third countries?(measures-to-facilitate-access-in-third-countries)
23. Are there mechanisms to improve the functioning and efficiency of markets not covered in this paper, particularly in the areas of equity and bond market functioning and liquidity?(mechanisms-not-covered-in-this-paper)
Comments on question 23:(comments-mechanisms-not-covered-in-this-paper)
24. In your view, are there areas where the single rulebook remains insufficiently developed?(areas-where-single-rulebook-insufficiently-developed)
25. Do you think that the powers of the ESAs to ensure consistent supervision are sufficient? What additional measures relating to EU level supervision would materially contribute to developing a Capital Markets Union?(esa-powers-sufficients)
26. Taking into account past experience, are there targeted changes to securities ownership rules that could contribute to more integrated capital markets within the EU?(targeted changes-to-securities-ownership-rules)
Comments on question 26:(comments-targeted changes-to-securities-ownership-rules)
27. What measures could be taken to improve the cross-border flow of collateral?(measures-to-improve-cross-border-flow-of-collateral)
27.1 Should work be undertaken to improve the legal enforceability of collateral and close-out netting arrangements cross-border?(improve-legal-enforceability)
Comments on question 27.1:(comments-improve-legal-enforceability)
28. What are the main obstacles to integrated capital markets arising from company law, including corporate governance? Are there targeted measures which could contribute to overcoming them?(main-obstacles)
29. What specific aspects of insolvency laws would need to be harmonised in order to support the emergence of a pan-European capital market?(harmonise-insolvency-laws)
30. What barriers are there around taxation that should be looked at as a matter of priority to contribute to more integrated capital markets within the EU and a more robust funding structure at company level and through which instruments?(priority-barriers-around-taxation)
31. How can the EU best support the development by the market of new technologies and business models, to the benefit of integrated and efficient capital markets?(eu-support-the-development)
32. Are there other issues, not identified in this Green Paper, which in your view require action to achieve a Capital Markets Union? If so, what are they and what form could such action take?(comments-other-issues)
Should you wish to provide additional information (e.g. a position paper, report) or raise specific points not covered by the questionnaire, you can upload your additional document(s) here:(file-upload)
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Are you replying as:
First name and last name:
Name of your organisation:
Name of the public authority:
Contact email address:
Is your organisation included in the Transparency Register?
(If your organisation is not registered, we invite you to register here, although it is not compulsory to be registered to reply to this consultation. Why a transparency register?)
If so, please indicate your Register ID number:
Type of organisation:
Please specify the type of organisation:
Type of public authority
Please specify the type of public authority:
Where are you based and/or where do you carry out your activity?
Please specify your country:
Field of activity or sector (if applicable):
Please specify which other financial services:
Please specify which non-financial sector:
Please specify your activity field(s) or sector(s):
Contributions received are intended for publication on the Commission’s website. Do you agree to your contribution being published?
(see specific privacy statement PDF)
1. Beyond the five priority areas identified for short term action, what other areas should be prioritised?
2. What further steps around the availability and standardisation of SME credit information could support a deeper market in SME and start-up finance and a wider investor base?
3. What support can be given to ELTIFs to encourage their take up?
4. Is any action by the EU needed to support the development of private placement markets other than supporting market-led efforts to agree common standards?
Comments on question 4:
5. What further measures could help to increase access to funding and channelling of funds to those who need them?
6. Should measures be taken to promote greater liquidity in corporate bond markets, such as standardisation? If so, which measures are needed and can these be achieved by the market, or is regulatory action required?
7. Is any action by the EU needed to facilitate the development of standardised, transparent and accountable ESG (Environment, Social and Governance) investment, including green bonds, other than supporting the development of guidelines by the market?
Comments on question 7:
8. Is there value in developing a common EU level accounting standard for small and medium-sized companies listed on MTFs? Should such a standard become a feature of SME Growth Markets? If so, under which conditions?
9. Are there barriers to the development of appropriately regulated crowdfunding or peer to peer platforms including on a cross border basis? If so, how should they be addressed?
10. What policy measures could incentivise institutional investors to raise and invest larger amounts and in a broader range of assets, in particular long-term projects, SMEs and innovative and high growth start-ups?
11. What steps could be taken to reduce the costs to fund managers of setting up and marketing funds across the EU? What barriers are there to funds benefiting from economies of scale?
12. Should work on the tailored treatment of infrastructure investments target certain clearly identifiable sub-classes of assets?
Comments on question 12:
12.1 If so, which of these should the Commission prioritise in future reviews of the prudential rules such as CRDIV/CRR and Solvency II?
13. Would the introduction of a standardised product, or removing the existing obstacles to cross-border access, strengthen the single market in pension provision?
14. Would changes to the EuVECA and EuSEF Regulations make it easier for larger EU fund managers to run these types of funds?
14.1 What other changes if any should be made to increase the number of these types of fund?
15. How can the EU further develop private equity and venture capital as an alternative source of finance for the economy?
15.1 In particular, what measures could boost the scale of venture capital funds and enhance the exit opportunities for venture capital investors?
16. Are there impediments to increasing both bank and non-bank direct lending safely to companies that need finance?
17. How can cross border retail participation in UCITS be increased?
18. How can the ESAs further contribute to ensuring consumer and investor protection?
19. What policy measures could increase retail investment?
19.1 What else could be done to empower and protect EU citizens accessing capital markets?
20. Are there national best practices in the development of simple and transparent investment products for consumers which can be shared?
21. Are there additional actions in the field of financial services regulation that could be taken to ensure that the EU is internationally competitive and an attractive place in which to invest?
22. What measures can be taken to facilitate the access of EU firms to investors and capital markets in third countries?
23. Are there mechanisms to improve the functioning and efficiency of markets not covered in this paper, particularly in the areas of equity and bond market functioning and liquidity?
Comments on question 23:
24. In your view, are there areas where the single rulebook remains insufficiently developed?
25. Do you think that the powers of the ESAs to ensure consistent supervision are sufficient? What additional measures relating to EU level supervision would materially contribute to developing a Capital Markets Union?
26. Taking into account past experience, are there targeted changes to securities ownership rules that could contribute to more integrated capital markets within the EU?
Comments on question 26:
27. What measures could be taken to improve the cross-border flow of collateral?
27.1 Should work be undertaken to improve the legal enforceability of collateral and close-out netting arrangements cross-border?
Comments on question 27.1:
28. What are the main obstacles to integrated capital markets arising from company law, including corporate governance? Are there targeted measures which could contribute to overcoming them?
29. What specific aspects of insolvency laws would need to be harmonised in order to support the emergence of a pan-European capital market?
30. What barriers are there around taxation that should be looked at as a matter of priority to contribute to more integrated capital markets within the EU and a more robust funding structure at company level and through which instruments?
31. How can the EU best support the development by the market of new technologies and business models, to the benefit of integrated and efficient capital markets?
32. Are there other issues, not identified in this Green Paper, which in your view require action to achieve a Capital Markets Union? If so, what are they and what form could such action take?

Should you wish to provide additional information (e.g. a position paper, report) or raise specific points not covered by the questionnaire, you can upload your additional document(s) here:

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