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AMF Italia - Associazione Intermediari Mercati Finanziari

AMF Italia

AMF Italia – Associazione Intermediari Mercati Finanziari represents the interests of the intermediaries active on the Italian financial markets, namely Italian investment firms, investment banks and subsidiaries of foreign investment services providers.

Lobbying Activity

Meeting with Marco Zanni (Member of the European Parliament, Shadow rapporteur)

15 Jan 2024 · Retail Investment Strategy

Response to Open finance framework

31 Oct 2023

Assosim expresses its general appreciation for the effort of the European Commission to establish a framework governing access to and use of customer data in finance, which could facilitate access to data also by smaller market participants at more proportionate costs. Nevertheless, in a constructive manner, the Association deems it useful to point out certain critical issues that could undermine the effective functioning of the open finance framework (please see attached).
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Meeting with Marco Zanni (Member of the European Parliament, Shadow rapporteur)

11 Oct 2023 · Retail Investment Strategy

Meeting with Marco Zanni (Member of the European Parliament, Shadow rapporteur)

15 Sept 2023 · Retail Investment Strategy

Response to EMIR Targeted review

20 Mar 2023

Please find our feedback in the document attached.
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Meeting with Irene Tinagli (Member of the European Parliament, Committee chair)

8 Nov 2022 · Meeting on Financial Issues

Response to Debt equity bias reduction allowance (DEBRA)

29 Jul 2022

ASSOSIM desidera ringraziare la Commissione per l'opportunità di fornire le allegate osservazioni in risposta alla consultazione pubblica sulla proposta di direttiva Debt-Equity Bias Reduction Allowance - “DEBRA”.
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Response to Revision of EU rules on Anti-Money Laundering (new instrument)

17 Nov 2021

Accogliamo con favore l’iniziativa avviata dalla Commissione europea di revisione della disciplina in oggetto, ai fini di creare un quadro più coerente che agevoli la conformità degli operatori soggetti alle norme AML/CFT. Le divergenze applicative stanno infatti causando non poche difficoltà agli operatori, soprattutto nei rapporti transfrontalieri e la previsione di disposizioni comuni, valevoli per tutti gli Stati membri – e, auspicabilmente, anche nei rapporti con paesi extra-Ue aventi regimi equivalenti - costituirebbe un prezioso ausilio per snellire le procedure di adeguata verifica, senza nulla togliere in termini di efficienza dei presidi. In tale contesto, desideriamo concentrare la nostra attenzione sul regolamento in materia di AML/CFT, che - trattandosi di normativa di immediata applicazione – rappresenta il più operativo dei testi posti in consultazione. In relazione ad esso formuliamo nell'allegato le osservazioni condivise con gli intermediari associati.
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Response to Capital markets – research on small and mid-sized companies and fixed income (updated rules in light of the COVID-19 pandemic)

11 Sept 2020

We share the objective of increasing the production of financial research on SMEs, the level of which is currently not adequate to support their funding needs on the capital market. Still, the solution proposed by the European Commission appears to be an unsuitable remedy to the relevant causes. As correctly perceived by the Commission, unbundling has had a negative impact on SME research. However, introducing an exception to this obligation only for SMEs risks worsening the demand for research on their financial instruments. The scarce production of SMEs research is a consequence of its relatively low demand from portfolio managers, who have, and will continue to have after the entry into force of the reform proposed by the Commission, difficulties in introducing SME financial instruments into the portfolios they manage. We are firmly convinced that the solution to the problem, rather than in the introduction of incentives on the research-demand side, is to be found in the introduction of incentives on the research-supply side. In such a perspective, various instruments may be available to the legislator: 1. To protect the market and the investors, research, not unlike other financial services, must be regulated and remunerated from a service perspective. The research service is a composite service, provided "as a package" by financial intermediaries: it implies a constant dialogue between a portfolio manager and the analyst (or their salespersons) and has as its object a plurality of issuers (SMEs and larger firms all together). In this "package mode”, the research is enjoyed and must, therefore, be remunerated by portfolio managers. The Commission proposal, by introducing a double regime for financial research (large vs. small companies), will be perceived by the investors as introducing a less protective regime concerning SMEs financial instruments; 2. It is also essential to establish objective criteria to define the fair price for research, below which it cannot be sold or purchased. As a matter of fact, the scope of the EU ban is currently limited to "free research". As highlighted in a study published in January this year by a working group set up by the Authorité des Marchés Financiers, though, significant doubts could be raised concerning the legitimacy of the pricing conditions under which the main "global financial players" currently provide access to their research. Irrespective of the need to verify in practice (by the relevant antitrust authorities) whether in individual cases (as argued in the document of the AMF) cross-subsidisation or even dumping hypothesis occur, there is no doubt that a research mis-selling at "cowardly" price is to be assimilated to research sold for free and included in the above ban; 3. Introduce an obligation for listed issuers that capitalize less than €1BLN to have at least 2 corporate brokers producing sponsored research. As already mentioned, the current insufficient SMEs coverage is to be linked to the scarcity of research demand for their financial instruments, which are characterized by a particularly low level of liquidity and as such are difficult to be included in the managers' investment strategies. In fact, portfolio managers find it hard to bear the cost of research on financial instruments not already included in the portfolios they manage. It is well known, however, that these financial instruments often represent good investment opportunities, of which a portfolio manager could hardly count other than thorough research that is legitimately made available to him free of charge (in that paid by the issuer itself); 4. Finally, national legislators should consider introducing tax benefits aimed at encouraging sponsored and non-sponsored research, the latter being indispensable to enable institutional investors and asset managers to take investment decisions also based on independent opinions.
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