Feedback (53)

  • Managed Funds Association (United States)
    21 June 2018 Business association
    Managed Funds Association (United States)

    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...

  • BETTER FINANCE (Belgium)
    21 June 2018 Non-governmental organisation (NGO)
    BETTER FINANCE (Belgium)

    BETTER FINANCE welcomes this opportunity to comment on the proposal amending Delegated Regulation (EU) 2017/565 supplementing MiFID II as regards organizational requirements and operating conditions for investment firms and defined terms for the purpose of that directive. Investment firms shall act in accordance with the best interest of their clients. As such, when providing investment advice and portfolio management, they must disclose...

  • French Asset Management Association (Association Française de la Gestion financière, AFG) (France)
    21 June 2018 Business association
    French Asset Management Association (Association Française de la Gestion financière, AFG) (France)

    AFG decided very early on to fully support the development of responsible investment in France. French asset management companies are fully committed to this approach and are adapting their offering to the concerns of their institutional and private investors by proposing products that entail varying degrees and types of commitment – SRI funds, integration of ESG criteria, shareholder engagement, thematic investing and so on – and have in...

  • Principles for Responsible Investment (United Kingdom)
    21 June 2018 Business association
    Principles for Responsible Investment (United Kingdom)

    The Principles for Responsible Investment (PRI) believes that dialogue between investors and clients on ESG interests and preferences is a necessary to a sustainable financial system and we welcome policy initiatives to encourage this dialogue. The PRI has traditionally focussed on ESG in investment rather than the point of sale dialogue on client ESG interests, we nevertheless have signatory data on asset consulting services and disclosure of...

  • European Association of Cooperative Banks (Belgium)
    21 June 2018 Business association
    European Association of Cooperative Banks (Belgium)

    The European Association of Co-operative Banks (EACB) is closely following the European Commission work on sustainable finance as this is a very important workstream for the EACB members due to the fact that co-operative banks, being local and regional banks, play a key role in sustainable financing. This is via sustainable investments or savings products, energy transition project financing, green financing to SMEs and energy efficiency...

  • FIR - FrenchSIF (France)
    21 juin 2018 Business association
    FIR - FrenchSIF (France)

    Le FIR - French SIF soutient pleinement l’idée de permettre l’engagement des épargnants en les questionnant sur leur préférence environnementale, sociale, sociétale et de bonne gouvernance. Afin de répondre à leurs aspirations, les épargnants français peuvent choisir des produits labellisés ISR ou climat (label TEEC). Ces labels sont respectivement pilotés par le ministère de l’économie et des finances et le ministère de la transition...

  • AIMA (Belgium)
    21 June 2018 Business association
    AIMA (Belgium)

    The Alternative Investment Management Association Limited (AIMA) welcomes the opportunity to respond to the proposal for a delegated regulation amending Regulation (EU) 2017/565 (‘MiFIR’) supplementing Directive 2014/65/EU (‘MiFID II’) as regards organisational requirements and operating conditions for investment firms and defined terms for the purposes of that Directive (the ‘draft delegated regulation’). Investor interest in responsible...

  • Finance Denmark (Denmark)
    21 June 2018 Business association
    Finance Denmark (Denmark)

    Finance Denmark strongly supports the proposals of sustainable finance and we think The European Commission’s proposals overall are a positive step towards a sustainable economy. The Commission´s initiative is an important part of the steps to achieve the necessary funding for the transition to a low-carbon, resource-efficient and circular economy. We acknowledge that the financial sector has a key role to play in reaching those goals. We work...

  • The Investment Association (United Kingdom)
    21 June 2018 Business association
    The Investment Association (United Kingdom)

    The Investment Association (IA) thanks the Commission for the opportunity to comment on proposed changes to the MiFID II Suitability Assessment. Asset managers are increasingly seeking to integrate an assessment of environmental, social and governance (ESG) factors in their investment process and decisions and to monitor and mitigate their risks and opportunities, where these factors are deemed to have a material impact on performance. Along...

  • 2°Investing Initiative (Germany)
    21 June 2018 Non-governmental organisation (NGO)
    2°Investing Initiative (Germany)

    For our feedback please see the attached file.

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