Asociación de Instituciones de Inversión Colectiva y Fondos de Pensiones
INVERCO
La Asociación persigue los siguientes fines: a) Representar los intereses de las Instituciones de Inversión Colectiva y de los Fondos de Pensiones, ante las Administraciones Públicas y, en general, ante cualquier organización representativa. b) Llevar a cabo una máxima coordinación en beneficio de todas las Instituciones integradas en la Asociación. c) Realizar cuantas gestiones estime convenientes en defensa de los intereses de los asociados. d) Establecer y fomentar las relaciones con otras entidades españolas o extranjeras, así como participar en organizaciones empresariales de ámbito nacional o internacional.
ID: 648651917120-02
Lobbying Activity
Meeting with Maria Luís Albuquerque (Commissioner) and
27 May 2025 · • SIU, in particular pension products and RIS • SF
Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)
22 May 2025 · SIU and SFDR
Meeting with Helene Bussieres (Head of Unit Financial Stability, Financial Services and Capital Markets Union)
13 May 2025 · Exchange of views on the Savings and Investments Union
Meeting with Jorge Martín Frías (Member of the European Parliament)
14 Nov 2024 · Retail Investment Strategy (RIS)
Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Nicolo Brignoli (Cabinet of Commissioner Mairead Mcguinness) and
12 Jan 2022 · Retail Investments Strategy
Response to Distance Marketing of Consumer Financial Services - Review of EU rules
24 Jun 2021
INVERCO welcomes the opportunity to comment on the intended review by the European Commission (EC) of the Directive on distance marketing of consumer financial services (hereinafter, the “Directive”). INVERCO (Spanish Association of Collective Investment Schemes and Pension Funds) represents more than 5,500 Collective Investment Schemes and more than 2,500 Pension Funds, with assets under management over EUR 570 billion.
INVERCO agrees on the statement made by EC in its inception impact assessment document on the limited effectiveness and added value of the Directive due to the approval of product specific legislation and horizontal legislation (ePrivacy Directive , General Data Protection Regulation ) after its entry into force. The Directive deals basically with the three following issues: (ii) information obligations to be provided to the consumer prior to the conclusion of the distance contract (pre-contractual information) (ii) the right of withdrawal of consumers for certain financial services/products and (iii) the ban on unsolicited services and communications from suppliers.
Regarding the information obligations, specific regulation has been introduced after its entry into force both for Collective Investment Institutions (CII) and Pension Products in the relevant EU directives (UCITS , AIFMD , IORP II) and the new PEPP regulation on the pre contractual information to be provided to the clients when providing services on a means of distance communication. On top of this, horizonal regulation on the rendering of financial services (MiFID II Directive ) and on the documentation to be handed to retail investors on investment products (PRIIPs Regulation ) deals also with the pre and post contractual information to be provided in the distance marketing of financial services and products. Therefore, a detailed framework on information obligations for the distance marketing of financial services and products, published after the entry into force of the Directive already applies.
Ban on unsolicited services regulated in the Directive is also currently sufficiently covered by the ePrivacy Directive and General Data Protection Regulation.
Therefore, we regard the alternatives 1 and 2 of the impact assessment document as the ones that best suit the purpose of both protecting consumers and reducing unnecessary burdens for financial service providers. In this sense a repeal of the Directive would be the best alternative, moving to the specific products legislation the specific parts of the Directive that actually are not covered in said legislation. i.e., the right of withdrawal (in case of CII, its non-application) could be moved to the specific product/services regulation. This solution would lead to a more clear and effective application of the legal framework on the distance rendering of services and eliminate the actual overlap of legislations.
On the contrary, a review of the Directive with the introduction of new information obligations for financial services providers would:
(i) enhance the actual overlap of regulations creating confusion both for providers and consumers, which would be opposed to the actual aim of the Commission to rationalize information available to investors and intermediaries, as stated in the MIFID II review road map published by the EU Commission.
(ii) lead to an over information for consumers which would have the unintended effect of discouraging them from engaging with said information before adopting their investment decisions and would not be in line with the Final report on the Capital Markets Union which recommends making disclosure obligations more coherent and streamlining them.
(iii) be burdensome for financial service providers which would also be opposed to the aim of enhancing access to capital markets for EU citizens and channeling investments to the real economy.,
Read full responseResponse to Institutional investors' and asset managers' duties regarding sustainability
31 Jul 2018
In INVERCO´s view, the purpose of these proposals is valued very positively, since to the extent that the capital flows are directed more easily towards activities that positively impact on the fulfillment of environmental, social and governance objectives, the recipients of said financing will conduct their model of business towards these objectives.
This approach, while practical, is a challenge for the financial sector, and in particular for the asset management industry. In this regard, it should be reminded that the asset management activity does not cover, "per se", the incorporation of ESG factors. Although in recent years the Asset managers have made an important progress, sometimes driven by specific regulations – the Shareholder Rights Directive (SRD) or the IORP Directive-, and sometimes by the own conviction of the Asset managers or, to a lesser extent, by the -limited- demand of ESG products by investors. Therefore it cannot be said that there is a generalized "know-how" in the asset management sector on the incorporation of ESG factors in their investment decision-making processes and risk management processes.
Therefore, the asset management industry will have to undertake the necessary transformations that will allow it to generalize the ESG investment in its sector, largely through the support of external experts and information sources, as there are few entities that can assume, nowadays, the internalization of these capabilities from a cost perspective.
Taking into account that the asset management industry is very varied across Europe, with entities of very different sizes, there is no doubt that smaller entities will face greater obstacles and difficulties when it comes to complying with the new regulations, all this in a context of narrowing of margins derived from compliance with other regulations (UCITS, FIA, IORP or MiFID, among others).
The foregoing does not prevent the proposals from being considered very positive, and that the general comment of this document focuses on highlighting, in recognition of the relevance of the objectives to be met, the importance that the future approved texts will be compatible with:
- Legal certainty, so that its scope of application, content, framework and calendar are of the utmost clarity, allowing recipients of these standards to comply with them and that the adaptations that are necessary to carry out in the ordinary development of its activity, which undoubtedly will be many and very relevant, can be planned in an orderly manner and put into practice, avoiding working on changing frames that oblige to do and undo, with the cost that this implies.
- Flexibility needed, through the approval of the regulatory framework in accordance with an orderly and sequential process, as well as the gradual and flexible application of the new provisions, through an approach that helps entities move forward on this important path, without burdening them with obligations whose fulfillment they can hardly assume.
Read full responseResponse to Institutional investors' and asset managers' duties regarding sustainability
31 Jul 2018
In INVERCO´s view, the purpose of these proposals is valued very positively, since to the extent that the capital flows are directed more easily towards activities that positively impact on the fulfillment of environmental, social and governance objectives, the recipients of said financing will conduct their model of business towards these objectives.
This approach, while practical, is a challenge for the financial sector, and in particular for the asset management industry. In this regard, it should be reminded that the asset management activity does not cover, "per se", the incorporation of ESG factors. Although in recent years the Asset managers have made an important progress, sometimes driven by specific regulations – the Shareholder Rights Directive (SRD) or the IORP Directive-, and sometimes by the own conviction of the Asset managers or, to a lesser extent, by the -limited- demand of ESG products by investors. Therefore it cannot be said that there is a generalized "know-how" in the asset management sector on the incorporation of ESG factors in their investment decision-making processes and risk management processes.
Therefore, the asset management industry will have to undertake the necessary transformations that will allow it to generalize the ESG investment in its sector, largely through the support of external experts and information sources, as there are few entities that can assume, nowadays, the internalization of these capabilities from a cost perspective.
Taking into account that the asset management industry is very varied across Europe, with entities of very different sizes, there is no doubt that smaller entities will face greater obstacles and difficulties when it comes to complying with the new regulations, all this in a context of narrowing of margins derived from compliance with other regulations (UCITS, FIA, IORP or MiFID, among others).
The foregoing does not prevent the proposals from being considered very positive, and that the general comment of this document focuses on highlighting, in recognition of the relevance of the objectives to be met, the importance that the future approved texts will be compatible with:
- Legal certainty, so that its scope of application, content, framework and calendar are of the utmost clarity, allowing recipients of these standards to comply with them and that the adaptations that are necessary to carry out in the ordinary development of its activity, which undoubtedly will be many and very relevant, can be planned in an orderly manner and put into practice, avoiding working on changing frames that oblige to do and undo, with the cost that this implies.
- Flexibility needed, through the approval of the regulatory framework in accordance with an orderly and sequential process, as well as the gradual and flexible application of the new provisions, through an approach that helps entities move forward on this important path, without burdening them with obligations whose fulfillment they can hardly assume.
Read full responseResponse to Institutional investors' and asset managers' duties regarding sustainability
31 Jul 2018
The purpose of these proposals is valued very positively, since to the extent that the capital flows are directed more easily towards activities that positively impact on the fulfillment of environmental, social and governance objectives, the recipients of said financing will conduct their model of business towards these objectives.
This approach, while practical, is a challenge for the financial sector, and in particular for the asset management industry. In this regard, it should be reminded that the asset management activity does not cover, "per se", the incorporation of ESG factors. Although in recent years the Asset managers have made an important progress, sometimes driven by specific regulations – the Shareholder Rights Directive (SRD) or the IORP Directive-, and sometimes by the own conviction of the Asset managers or, to a lesser extent, by the -limited- demand of ESG products by investors. Therefore it cannot be said that there is a generalized "know-how" in the asset management sector on the incorporation of ESG factors in their investment decision-making processes and risk management processes.
Therefore, the asset management industry will have to undertake the necessary transformations that will allow it to generalize the ESG investment in its sector, largely through the support of external experts and information sources, as there are few entities that can assume, nowadays, the internalization of these capabilities from a cost perspective.
Taking into account that the asset management industry is very varied across Europe, with entities of very different sizes, there is no doubt that smaller entities will face greater obstacles and difficulties when it comes to complying with the new regulations, all this in a context of narrowing of margins derived from compliance with other regulations (UCITS, FIA, IORP or MiFID, among others).
The foregoing does not prevent the proposals from being considered very positive, and that the general comment of this document focuses on highlighting, in recognition of the relevance of the objectives to be met, the importance that the future approved texts will be compatible with:
- Legal certainty, so that its scope of application, content, framework and calendar are of the utmost clarity, allowing recipients of these standards to comply with them and that the adaptations that are necessary to carry out in the ordinary development of its activity, which undoubtedly will be many and very relevant, can be planned in an orderly manner and put into practice, avoiding working on changing frames that oblige to do and undo, with the cost that this implies.
- Flexibility needed, through the approval of the regulatory framework in accordance with an orderly and sequential process, as well as the gradual and flexible application of the new provisions, through an approach that helps entities move forward on this important path, without burdening them with obligations whose fulfillment they can hardly assume.
Read full responseResponse to Institutional investors' and asset managers' duties regarding sustainability
11 Dec 2017
INVERCO supports the need to improve undertakings' disclosure of social and environmental information, as well as, developing positions towards considering ESG aspects and integrate them on a voluntarily basis in their asset allocation decisions. Nevertheless, “comply or explain” should be the fundamental transparency principle.
From our point of view, there should not be any compulsory ESG rules in the investment strategy/asset allocation, given the many different approaches for the implementation of ESG factor. The necessary leeway for Pension Funds or CIS in finding the appropriate way to implement ESG aspects in the investment process need to be guaranteed.
Moreover, social investment strategies, should be clearly distinguished and separated from ESG integration, since social investment strategies also seek purposes not always related to the delivery of a financial return. Such strategies, often involve a narrowing of the available investment universe through the screening of sectors or stocks on ethical grounds.
CIS and Pension Funds, as institutional investors, have the opportunity to vote with their feet, and so, the investment horizon should be taken into account to provide the appropriate flexibility and proportionality in terms of information of assets and engagement. Member States shall allow CIS and Pension Funds to take into account the potential long-term impact of investment decisions on environmental, social, and governance factors, nonetheless, as stated above, a further compulsory consideration of ESG aspects should not be required.
The concept of fiduciary duty in the EU is clear and is not an impediment to responsible investment. Indeed, the duty of care to their clients is a common EU standard, which adapts to reflect market practice and investment industry norms.
ESAs should not supervise on ESG integration. Supervision is still a national matter and should be left to NCA’s. Besides, ESAs should not deliver EU-wide definitions about what sustainable investment stands for and what is not. That should be set up individually and may differ considerably between different CIS and IORPs.
In addition, any integration of ESG criteria into pan-European stress tests and excessive ESG related reporting requirements should be avoided since it would not help to make ESG-related investing more wide-spread, but more burdensome.
Read full response