Managed Funds Association (“MFA”) welcomes the opportunity to provide comments to the European Commission (the “Commission”) on its proposal for a delegated regulation as regards organisational requirements and operating conditions for investment firms (the “Draft Delegated Regulation”). MFA supports the European Commission’s aim of promoting sustainable finance within the EU, and of closing the investment gap required to meet European climate and energy targets. Environmental, Social and Governance (“ESG”) factors are of increasing importance to many investors both in the EU and in the United States, and we welcome the Commission’s efforts to enable the asset management industry and the finance sector more generally to meet this increasing demand for sustainability.
MFA supports in particular the aim of the High-Level Expert Group (“HLEG”) of increasing transparency around products that are “green” or “sustainable” in nature, particularly products that are marketed as such. This increased transparency should enable clients to better assess whether the products and services that they purchase meet their sustainability criteria, and should also allow portfolio managers to make a more informed assessment of how sustainable their overall service is. We also support the client driven approach that the Commission is proposing, which is consistent with the views we expressed in our January 22, 2018 joint letter with the Alternative Investment Management Association, in response to the Commission’s prior public consultation.
Please see the attached comment letter for MFA's detailed comments on the Proposed Delegated Regulation.
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