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Strengthening the consideration of sustainability risks and factors for financial products (Directive (EU) 2017/593)

Banking and financial services

In the Action Plan on Sustainable Finance (COM/2018/097 final) the Commission expressed intention to clarify fiduciary duties and increase transparency in the field of sustainability risks and sustainable investment opportunities with the aim to: - reorient capital flows towards sustainable investment; - degradation and social issues; - foster transparency and long-termism in financial and economic activity.

Links

Public consultation

ID: 12067

Lobbying Activity

30 responses

Consultation response

WWF European Policy Programme, 6 Jul 2020

The European Commission has added in all the considered Articles ‘including any sustainability preferences’ (especially for the product governance obligations – Delegated Directive (EU) 2017/593) or ‘including his or her sustainability preferences/factors’ (in the Delegated Directive (EU) 2017/565…

Consultation response

Fédération bancaire française, 6 Jul 2020

The FBF welcomes the EC consultation on the amendments to the MiFID II Delegated Regulation (EU) 2017/565 and Delegated Directive (EU) 2017/593 as regards the integration of sustainability factors, risks and preferences. I. MiFID ESG consultations 1. Implementation timeline • Investment firms will…

Finance industry urges nine-month delay for ESG rules

Association for Financial Markets in Europe, 6 Jul 2020

AFME requests a nine-month implementation period after Member States transpose the directive, warning the current timeline could leave firms only one day to comply. They want flexibility to exclude products without sustainability elements and exemption from reviewing pre-existing instruments for ESG factors.
This would give them time to upgrade IT systems and avoid costly reviews of existing products.
Sustainable investors lose faster access to ESG information about existing financial products.

European Banking Federation Seeks Delay for Sustainability Rules

European Banking Federation, 6 Jul 2020

The federation requests more implementation time and clearer definitions of sustainability preferences. They argue current timelines are insufficient given material uncertainties and the need to adapt IT infrastructure. They want flexibility to distribute non-ESG products to clients with ESG preferences for portfolio diversification.
This would reduce compliance costs and give banks more time to update internal procedures and systems.
Sustainable investment advocates lose faster implementation of transparency rules for ESG products.

Consultation response

Finanssiala ry - Finance Finland, 6 Jul 2020

Finance Finland's (FFI) response to the Commission’s draft amendments on the integration of sustainability considerations into MiFID II • The definition of ESG-compliant products should not be narrowed under MiFID. The definition of sustainability preferences should refer to the existing…

Consultation response

Invest Europe, 6 Jul 2020

Please note the introduction in Invest Europe’s response to the Draft Delegated Regulation (EU) 2017/565 about the relevance and application of MiFID in a private equity context. The proposed amendments to this Delegated Directive seem fine for the circumstances in which the product governance…

Consultation response

Associazione Bancaria Italiana, 6 Jul 2020

This document constitutes ABI's contribution to the consultation launched by the European Commission on the amendments to the MiFID II Delegated Regulation (EU) 2017/565 and the Delegated Directive (EU) 2017/593 regarding the integration of sustainability factors, risks and preferences into certain…

Consultation response

Asociación Española de Banca, 6 Jul 2020

The Spanish Banking Association welcomes the opportunity to respond to the draft amendments of the MiFID Delegated Directive. Please find enclosed our full response.

ICI Global Urges Including All Sustainable Products in MiFID

Investment Company Institute, 6 Jul 2020

The commission should revise its definition of 'sustainability preferences' to include SFDR Article 8 products. Narrowing this definition would effectively eliminate an established category of sustainable financial products.
This would allow asset managers to continue offering a diverse range of ESG strategies.
Smaller firms face insurmountable entry barriers due to costly and complex disclosure requirements.

Consultation response

European Association of Co-operative Banks, 6 Jul 2020

The EACB welcomes the opportunity to provide its feedback on the draft delegated acts to MiFID II, UCITS Directive, AIFMD, and IDD stemming from the goals of the European Commission’s ‘Action Plan: Financing Sustainable Growth’ to (i) integrate sustainability within investment advice (Action 4);…

Consultation response

Association Française de la Gestion financière, 6 Jul 2020

Please find in the document attached more detailed feedback from the French Asset Management Association (AFG) on these proposals The proposed approach to the definition of sustainability preferences in Article 1 of the Delegated Act seems overly restrictive: - It ‘goldplates’ level 1 and…

Consultation response

Fairshare Educational Foundation (ShareAction), 6 Jul 2020

ShareAction welcomes the proposals to amend delegated regulations under MiFID II to ensure a better integration of sustainability preferences and risk into organisational requirements and operating conditions for investment firms. However, we believe more granular requirements are needed on the…

Consultation response

European Fund and Asset Management Association, 6 Jul 2020

EFAMA has always been a firm supporter of creating a strong framework for sustainable investing which facilitates the transition to a more sustainable European economy. In this context, we see the Commission’s work on integrating sustainability considerations into MiFID II as an essential…

European savings banks urge harmonized sustainability rules and deadlines

European Savings and Retail Banking Group, 6 Jul 2020

The group calls for alignment between different EU investment rules to avoid conflicting labels. They request that target markets remain broad to prevent overwhelming clients with complex questions. Finally, they advocate for a single implementation date across different sustainable finance laws.
Aligning rules reduces the administrative burden and technical complexity of labeling financial products.
Inconsistent deadlines and complex questions could confuse retail investors or cause misinformation.

Consultation response

European Association of Public Banks and Funding agencies AISBL, 6 Jul 2020

Misalignment between MiFID II Delegated Acts and SFDR when defining sustainability preferences The new provisions of Article 2(7)(b) MiFID II Delegated Regulation and Article 1(5) second bullet point MiFID II Delegated Directive extend the definition of “sustainability preferences” by referring to…

Consultation response

Nederlandse Vereniging van Banken / Dutch Banking Association, 2 Jul 2020

The NVB would like to respond to the proposed amendments regarding Suitability and Product Governance, consolidated in one reaction. Please find our response attached.

Consultation response

The Alternative Investment Management Association Limited, 6 Jul 2020

AIMA and MFA have been actively engaging on the topic of sustainable finance with the European Commission and European policy-makers to contribute to the development of an effective and impactful sustainable finance environment. Our engagement seeks to ensure that investors and market players have…

Consultation response

International Capital Market Association, 6 Jul 2020

In line with the points raised under the consultation on the integration of sustainability risks in UCITS, the Asset Management and Investors Council of ICMA would suggest to the EC to consider similar changes regarding the integration of sustainability risks in investment firms (MiFID). In…

Consultation response

Aviva Plc, 6 Jul 2020

Aviva welcomes the publication of this suite of draft Delegated Acts, which implement important parts of the Sustainable Finance Action plan. We strongly support the policy intent to incorporate sustainability into suitability assessments, fiduciary duties and organisational requirements.…

Consultation response

The Investment Association, 6 Jul 2020

Overarching Comment As investment managers, we seek to deliver on our clients’ investment goals, including the generation of long-term sustainable returns and, where appropriate to the investor, allocation of capital to investment strategies with environmental or social characteristics or in the…

Consultation response

Principles for Responsible Investment, 6 Jul 2020

The proposed amendments to the delegated acts underpinning MiFID state that sustainability risks should be considered in risk management, conflict of interest and governance, but do not directly address the need to integrate sustainability risks when determining how to act in the best interests of…

Schroders urges EU to align ESG product rules with SFDR

Schroders Investment Management (Europe) SA, 6 Jul 2020

Schroders requests removing extra criteria for products promoting environmental or social characteristics. They argue the draft incorrectly adds sustainability requirements that conflict with existing laws. They also want rules to acknowledge that manufacturers often do not distribute products.
This prevents smaller investment firms from being forced into burdensome reporting requirements.
Investors lose access to variety and face confusion from conflicting product definitions.

Consultation response

Invesco Management SA, 6 Jul 2020

The overarching objectives set out in the European Commission’s Sustainable Finance Action Plan is to re-orient capital flows towards a more sustainable economy and to mainstream sustainability. The ambition being to incentivise financial market participants to offer sustainable investing options…

Consultation response

Swedish Securities Markets Association (Swedish: Föreningen Svensk Värdepappersmarknad), 6 Jul 2020

See attachment with SSMA full response. Key issue: The SSMA has several concerns in respect of the proposed new definition of “sustainability preferences” in Article 1 and 2 of MiFID II delegated acts. In particular, the following issues should be further analysed: The SFDR distinguishes…

Consultation response

Die Deutsche Kreditwirtschaft, 6 Jul 2020

1. The definitions of sustainability preferences in MiFID II Delegated Regulation (DelReg) and MiFID II Delegated Directive (DelDir) are not entirely identical. In the DelDir, the sustainability products are set out in bullet points, in the DelReg with (a) and (b). The version in the DelReg is…

Consultation response

Association Française des Marchés Financiers, 6 Jul 2020

AMAFI welcomes the opportunity to give feedbacks on European Commission proposed amendments to delegated acts under MiFID II to include sustainability factors into the advice that investment firms offer to individual clients. Indeed, AMAFI pays particular attention to the development of ESG…

Consultation response

Novamont SpA, 3 Jul 2020

Novamont welcomes the EU’s action plan on sustainable finance. To further improve the initiative we recommend to address, within the activities that provide genuine long-term benefits for society, those that allow to protect and restore natural resources from a systemic perspective. The use of…

Consultation response

Associação Portuguesa para a Defesa do Consumidor, 6 Jul 2020

DECO – the Portuguese Consumer protection Association, welcomes and supports the amendments proposed. These measures are necessary in order to foster the implementation of the Green Deal, the promotion of sustainability, and in particular sustainable finance. It is crucial to have mandatory…

Consultation response

BIPAR - European Federation of Insurance Intermediaries, 6 Jul 2020

BIPAR welcomes the opportunity provided by the European Commission to comment on its proposed Delegated Regulation amending the Delegated Regulation (EU) 2017/565 as regards the integration of sustainability factors, risks and preferences into certain organisational requirements and operating…

Consultation response

Dutch Fund and Asset Management Association, 3 Jul 2020

The Dutch Fund and Asset Management Association (DUFAS) welcomes the opportunity to respond to the draft amendments of the MiFID Delegated Acts. Please find enclosed our full response, where we have consolidated our comments to the proposed amendments regarding Suitability and Product Governance in…