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Investment Company Institute

ICI

ICI is a leading global association representing the asset management industry and individual investors.

Lobbying Activity

Meeting with Arba Kokalari (Member of the European Parliament)

21 Jan 2026 · Financial Markets Regulation

Meeting with Philippe Thill (Cabinet of Commissioner Maria Luís Albuquerque) and Invest Europe and

28 Nov 2025 · Exchange on the development of Level 2 and 3 measures in the area of AML.

Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur)

21 Oct 2025 · Securitisation

Meeting with Emiliano Tornese (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

16 Oct 2025 · Exchange of views about the state of the Macroprudential framework for NBFI.

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

26 Sept 2025 · Simplification, EU competitiveness

Meeting with Cristina Dias (Cabinet of Commissioner Maria Luís Albuquerque), Larisa Dragomir (Cabinet of Commissioner Maria Luís Albuquerque)

26 Sept 2025 · Savings and Investments Union

Meeting with Michael Hager (Cabinet of Commissioner Valdis Dombrovskis)

25 Sept 2025 · Competitiveness in Europa Transatlantic relations

Meeting with Larisa Dragomir (Cabinet of Commissioner Maria Luís Albuquerque)

4 Sept 2025 · Regulatory developments in the asset management sector

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Rapporteur) and AMUNDI AM

22 Jul 2025 · Retail investment strategy

Investment Company Institute urges EU account blueprint prioritizing investor choice

4 Jul 2025
Topic — European Commission recommendation on savings and investment account design and tax treatment.
Message — The organization requests a blueprint that provides investor choice of products and providers, simplified advice, digital accessibility, and tax incentives. They emphasize the account should be an investment vehicle, not a specific product, and should avoid geographical investment restrictions.123
Why — This would allow them to offer UCITS funds through streamlined distribution channels to retail investors.45
Impact — Domestic European companies lose preferential access to retail capital if geographic restrictions are rejected.67
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Meeting with Helene Bussieres (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

26 Jun 2025 · Exchange of views on the targeted consultation on integration of EU capital markets

Meeting with Maria Raffaella Assetta (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

18 Jun 2025 · U.S. Tax Bill

ICI urges EU to simplify sustainable finance disclosure rules

30 May 2025
Topic — Revision of EU rules on sustainable finance disclosure to improve usability and prevent greenwashing.
Message — The institute requests simplifying retail disclosures while removing mandatory requirements for professional clients. They also propose eliminating entity-level reporting to avoid duplication with other European regulations.123
Why — This would lower compliance costs and shield firms from liability related to unreliable data.45
Impact — Transparency groups lose access to mandatory firm-wide data on negative investment impacts.6
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Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

14 Apr 2025 · Sustainability Omnibus

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

10 Apr 2025 · EU economy

Meeting with Helene Bussieres (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

27 Mar 2025 · Roundtable on the SIU Communication and its implications for the Asset Management Sector

Investment Company Institute urges overhaul of EU securitisation rules

25 Mar 2025
Topic — The European Commission is conducting a holistic review of the EU's securitisation regulatory framework.
Message — ICI recommends simplifying due diligence by using existing fund rules and removing detailed reporting. They also call for adjusting capital charges to better reflect actual investment risks.12
Why — These changes would reduce compliance costs and provide asset managers with more investment choices.3
Impact — Regulators would lose access to the granular data currently used for market oversight.4
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Meeting with Andrea Beltramello (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

21 Mar 2025 · ICI presented their views on successful features of savings and investment accounts and successful international examples such as NISA and 401k/IRA. Potential benefits of investment accounts beyond just tax incentives were discussed.

Investment Company Institute urges creation of European Savings and Investment Account

5 Mar 2025
Topic — EU initiative to connect citizen savings to productive investments and strategic priorities.
Message — ICI strongly recommends creation of a European Savings and Investment Account (ESIA) with investor choice of products and providers, simplified advice, and digital accessibility. The account should leverage the UCITS framework and avoid restrictions on eligible investments or geographical limitations.123
Why — This would expand access to capital markets for their 100 million retail clients and reduce regulatory fragmentation costs.456
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and

21 Feb 2025 · Recent developments in the US

Meeting with Michael Hager (Cabinet of Commissioner Valdis Dombrovskis)

21 Feb 2025 · Economic situation in the US and the EU

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Rapporteur)

20 Feb 2025 · Stratégie d'investissement de détail

Meeting with Mario Nava (Director-General Employment, Social Affairs and Inclusion)

20 Feb 2025 · Exchange of views on the Savings and Investment Union

Meeting with Emiliano Tornese (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

31 Jan 2025 · Macroprudential review for NBFI

Meeting with Cristina Dias (Cabinet of Commissioner Maria Luís Albuquerque), Larisa Dragomir (Cabinet of Commissioner Maria Luís Albuquerque)

31 Jan 2025 · Exchange on the Savings and Investments Union

Investment Company Institute urges EU to cut regulatory burdens on asset managers

30 Jan 2025
Topic — EU strategy to remove barriers hindering single market development and cross-border services.
Message — The organization requests the EU reduce reporting obligations by 25%, eliminate regulatory fragmentation among Member States, and balance economic growth with investor protection in financial services legislation.123
Why — This would lower compliance costs and enable funds to scale up across borders.45
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Meeting with Eero Heinäluoma (Member of the European Parliament) and Huawei Technologies and Business Software Alliance

3 Oct 2024 · Current Affairs

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament) and Société Générale

3 Oct 2024 · Capital Markets Union /EU competitiveness

Meeting with Fernando Navarrete Rojas (Member of the European Parliament)

3 Oct 2024 · Presentation as an econ member

Meeting with Irene Tinagli (Member of the European Parliament)

2 Oct 2024 · Courtesy meeting

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Rapporteur) and JPMorgan Chase & Co. and

11 Sept 2024 · Retail Investment Strategy

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Patricia Reilly (Cabinet of Commissioner Mairead Mcguinness) and

19 Jun 2024 · Capital Markets Union

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

19 Jun 2024 · CMU

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

23 Apr 2024 · CMU in general.Retail investment Strategy and Macroprudential Stability.

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

9 Apr 2024 · Non-Bank Financial Intermediation (NBFI)

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Rapporteur)

13 Feb 2024 · Retail investment Strategy

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

16 Nov 2023 · RIS, SFDR and financial stability

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Patricia Reilly (Cabinet of Commissioner Mairead Mcguinness)

6 Nov 2023 · Retail Investment Strategy , UCITS funds

Meeting with Isabel Benjumea Benjumea (Member of the European Parliament)

25 Oct 2023 · RIS

Meeting with Mairead McGuinness (Commissioner) and

18 Jul 2023 · Distribution of Retail financial products

Meeting with Isabel Benjumea Benjumea (Member of the European Parliament, Rapporteur)

21 Apr 2023 · AIFMD

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

20 Apr 2023 · Corporate sustainability due diligence, sustainable finance, retail investment strategy

Meeting with Catharina Rinzema (Member of the European Parliament)

2 Mar 2023 · Due diligence

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Patricia Reilly (Cabinet of Commissioner Mairead Mcguinness)

27 Oct 2022 · retail investment strategy, sustainable finance, asset management

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

27 Oct 2022 · Sustainable Finance

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

30 Jun 2022 · Investment fund regulation

Meeting with Dārta Tentere (Cabinet of Commissioner Mairead Mcguinness), Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

9 Jun 2022 · Sustainable finance, CSDDD

Investment Company Institute urges EU digital fund reforms

31 May 2022
Topic — EU retail investment strategy covering investor protections and capital market participation.
Message — The organization requests a pan-European marketing regime to eliminate cross-border distribution barriers, default e-delivery for all disclosures, and unified cost categorization splitting distribution and management fees. They seek to enable digital innovation including portable digital identity frameworks and non-document disclosure formats.123
Why — This would reduce compliance costs and expand cross-border fund distribution opportunities.45
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Response to Central securities depositories – review of EU rules

25 May 2022

ICI Global Recommendations on the Central Securities Depositories Regulation REFIT ICI Global’s members manage EUR 39 trillion in regulated investment funds around the world, and we have a strong interest in a well-functioning securities market in the EU. The Central Securities Depositories Regulation (CSDR) should aim to increase the safety and efficiency of securities settlement and settlement infrastructures, but the mandatory buy-in regime (MBR) is not consistent with this and will not be able to achieve its intended purpose. Therefore, the MBR should be removed or substantively reformed to avoid unintended harm to markets and fund investors. EU settlement efficiency has improved substantially over the years, reducing the volume of failed trades to internationally consistent levels – a trend that will be supported by the CSDR’s matching and settlement failure procedures. The MBR will do the opposite. Dealers and market makers will naturally consider the potential cost of a mandatory buy-in. As a result, broker dealers may trade less of these instruments, or add a premium to the bid-ask spread to offset for the potential cost of a fail trade. Simply put, the greater the risk of a buy-in for a specific security the less inclined dealers and market makers will be to trade these securities. A similar consideration will apply for securities lending. A MBR will thus negatively impair liquidity, increasing costs, disadvantaging investors, and reducing the EU’s competitiveness. It should be removed. Cash penalties should be the primary mechanism to reduce settlement failures in the EU. Cash penalty provisions are adequate to provide incentives for market participants to match and settle trades in a timely fashion, ultimately improving settlement efficiency for EU markets overall. While we believe EU policymakers should remove the MBR from the CSDR, if a buy-in regime is retained then it should be made voluntary, giving the non-failing party the ability to use the buy-in rule if in their best interest – this provides a guaranteed layer of investor protection and safety in the settlement system and is consistent with international best practices. The MBR should be framed in a predictable and proportionate manner. The vagueness of the criteria and of the examination procedure in the current proposal could result in implementing the MBR in scenarios that would hamper investors and capital markets. The MBR should only be implemented under the following conditions – building on those in the Commission’s proposal: - As a last resort measure when other possibilities (e.g., recalibrating cash penalty levels) have not sufficiently increased the settlement efficiency as measured over a timeframe which takes account of pre-CSDR settlement failure levels; - Based on a comparison assessment of only those third-country markets which have introduced MBRs to reduce the level of settlement failures; - Only if it can be demonstrated that mandatory buy-ins will not have a negative impact on fund investors, including in, but not limited to, stress scenarios. In any case, the MBR should retain sufficient flexibility for the non-failing party to determine how best to resolve a failed trade in their best interest (e.g., through sourcing securities or cash compensation.) Such an approach retains the possibility, when a buy-in is not possible, for the receiving party to choose the alternative of cash compensation or to defer the execution of the buy-in to a later stage.
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Meeting with Danuta Maria Hübner (Member of the European Parliament, Rapporteur)

5 Apr 2022 · MiFIR Review

Response to Long Term Investment Funds – Review of EU rules

24 Mar 2022

Attached please find ICI Global's feedback on the Commission's ELTIF review proposal.
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Response to Alternative Investment Fund Managers – review of EU rules

24 Mar 2022

Attached please find ICI Global's feedback on the Commission's AIFMD review proposal.
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Meeting with Mairead McGuinness (Commissioner) and

16 Mar 2022 · EC Priorities for 2022 CMU sustainable finance MMFs RIS

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Afore Consulting

9 Nov 2021 · Sustainable finance, Capital Markets Union

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

9 Nov 2021 · AIFMD, CMU

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and Afore Consulting

9 Nov 2021 · Sustainable Finance

Response to New EU system for the avoidance of double taxation in the field of withholding taxes

25 Oct 2021

The Investment Company Institute (ICI), including ICI Global—on behalf of collective investment vehicle (CIV) investors— supports strongly a widely applicable, practical, and reliable mechanism for providing investors with appropriate treaty relief. The varied procedural requirements imposed throughout the European Union (EU) on cross-border investors impose substantial burdens on investors, service providers, governments, and the markets. The Capital Markets Union (CMU) initiative is an excellent opportunity for addressing these long-standing and well-known barriers to cross-border investment. The attached letter provides the findings that explain our strong support for this initiative.
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Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and Afore Consulting

20 Sept 2021 · AIFMD,/UCITS review Brexit MMFs

Response to Review of the Benchmark Regulation

24 Sept 2020

ICI Global appreciates the opportunity to provide feedback on the European Commission’s proposal to amend the European Union Benchmark Regulation (BMR). Like market participants around the globe, regulated funds are actively preparing for LIBOR discontinuation and implementing programs to transition to alternative reference rates. We support the Commission in addressing one of the most intractable issues concerning LIBOR discontinuation through this proposal. In particular, we appreciate the Commission’s approach in considering industry-recommended replacement rates to discontinued benchmarks and recognizing the need for coordination to prevent disruptions to the financial system. We recommend that the Commission build on the strengths of its BMR proposal by providing consistent solutions for the market, clarifying the legal authority of the BMR over multijurisdictional contracts, synchronizing the conventions for LIBOR replacement rates, and promoting a comprehensive approach to all EU legacy contracts.
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ICI Global Urges Including All Sustainable Products in MiFID

6 Jul 2020
Topic — The EU is integrating sustainability factors and preferences into financial product suitability and governance.
Message — 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.12
Why — This would allow asset managers to continue offering a diverse range of ESG strategies.3
Impact — Smaller firms face insurmountable entry barriers due to costly and complex disclosure requirements.4
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ICI Global urges EU to include broader sustainable products

6 Jul 2020
Topic — The European Commission is updating financial rules to integrate sustainability preferences.
Message — ICI Global requests revising the definition of 'sustainability preferences' to include both Article 8 and Article 9 products. They argue the current proposal effectively eliminates a key category of sustainable investments.12
Why — This would maintain the market for diverse ESG products and prevent high compliance costs.3
Impact — Retail investors lose access to diverse strategies, and smaller firms face high barriers.4
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ICI Global urges EU to drop adverse impact rules

6 Jul 2020
Topic — The EU is updating investment rules to integrate sustainability risks into financial management.
Message — ICI Global urges the Commission to remove requirements regarding adverse sustainability impacts. They also oppose changes to organizational, risk management, and senior management rules.12
Why — This avoids new reporting burdens and potential conflicts with legal duties to clients.34
Impact — Environmental groups lose transparency regarding the negative societal effects of investment decisions.5
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Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

19 Nov 2019 · CMU, sustainable finance

ICI Global Demands Sequencing EU Taxonomy Before New Disclosure Rules

23 Aug 2018
Topic — Clarifying sustainability duties for institutional investors and investment managers regarding financial materiality.
Message — The organization recommends completing the EU sustainability taxonomy before implementing disclosure rules and extending implementation to 24 months. They also request more detail in primary legislation to avoid market uncertainty.12
Why — Coordinated implementation reduces compliance risks and avoids an inconsistent patchwork of legislative requirements.3
Impact — Non-EU investors may lose interest in European funds if mandatory sustainability rules ignore their preferences.4
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Response to Reducing barriers to cross-border distribution of investment funds

10 May 2018

ICI Global [1] lauds the European Commission’s (“Commission”) effort to remove barriers to cross-border fund distribution. [2] We encourage the co-legislators to agree ambitious changes to ease distribution, lower investor costs, and increase investor fund choices and recommend the following amendments to the Commission’s proposals (discussed in more detail in the attached position paper): • Amend the Commission’s proposal to reflect clearly its intent to prohibit host Member States from requiring a physical presence to be established by either the UCITS management company or an appointed third entity to provide facilities to service investors; [3] • Enable all management companies to pre-market funds (not just AIFMs), including through the presentation of draft and near-final information documents to investors (e.g. draft offering memorandum); • Clarify that the provision of information on investment strategies or investment ideas to third-party distributors does not constitute pre-marketing; • Clarify that after a fund’s establishment, own-initiative subscriptions from investors to whom a fund did not pre-market shall not trigger a marketing notification; • Introduce provisions to enable a UCITS fund to access the single market passport through a single notification, [4] akin to the registration of EuVECA[5] and EuSEF[6] and the MiFID services passport; [7] • Extend the scope of ESMA’s mandate to standardise the content and transmission of marketing notifications [8] to include the standardisation of updates to notifications that have been previously submitted; • Expand the proposed ESMA central database of funds and management companies [9] to act as a single central “hub” for notifications and fund documentation (e.g., KIIDs); • Remove the proposed conditions for management companies to discontinue marketing in a host Member State because these conditions do not enhance investor protections afforded by existing obligations and may create unfairness between exiting and remaining fund investors. [10] As noted by the Regulatory Scrutiny Board, [11] we recommend that the Commission continue to examine factors that affect cross-border distribution not covered by the initiative, including other impediments and barriers (e.g. tax and administrative arrangements) to the offering of funds and detract from the attractiveness of cross-border investment. [1] ICI Global carries out the international work of the Investment Company Institute, the leading association representing regulated funds globally. ICI’s membership includes regulated funds publicly offered to investors in jurisdictions worldwide, with total assets of US$29.2 trillion. ICI seeks to encourage adherence to high ethical standards, promote public understanding, and otherwise advance the interests of regulated investment funds, their managers, and investors. ICI Global has offices in London, Hong Kong, and Washington, DC. [2] Proposal for a regulation on facilitating cross-border distribution of collective investment funds and amending Regulations (EU) No 345/2013 and (EU) No 346/2013 and Proposal for a directive amending Directive 2009/65/EC and Directive 2011/61/EU with regard to cross-border distribution of collective investment funds [3] Local facilities to perform the tasks specified in the revised Article 92 to the UCITS Directive (2009/65/EC). [4] Building on the proposals in Article 11 of proposed Regulation to standardise notifications. [5] New Article 14a(7) to the EuVECA Regulation [6] New Article 15a(7) to the EuSEF Regulation [7] Article 34, MIFID II and Article 92, MIFID in respect of the provision of certain investment services by AIFMs. [8] Article 11, proposed Regulation. [9] Article 10, proposed Regulation. [10] Proposed new Article 83a to the UCITS Directive contained in Article 1(7), proposed Directive [11] Opinion of the Regulatory Scrutiny Board SEC(2018)129 final.
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Response to Directive on cross-border distribution of investment funds

10 May 2018

ICI Global [1] lauds the European Commission’s (“Commission”) effort to remove barriers to cross-border fund distribution. [2] We encourage the co-legislators to agree ambitious changes to ease distribution, lower investor costs, and increase investor fund choices and recommend the following amendments to the Commission’s proposals (discussed in more detail in the attached position paper): • Amend the Commission’s proposal to reflect clearly its intent to prohibit host Member States from requiring a physical presence to be established by either the UCITS management company or an appointed third entity to provide facilities to service investors; [3] • Enable all management companies to pre-market funds (not just AIFMs), including through the presentation of draft and near-final information documents to investors (e.g. draft offering memorandum); • Clarify that the provision of information on investment strategies or investment ideas to third-party distributors does not constitute pre-marketing; • Clarify that after a fund’s establishment, own-initiative subscriptions from investors to whom a fund did not pre-market shall not trigger a marketing notification; • Introduce provisions to enable a UCITS fund to access the single market passport through a single notification, [4] akin to the registration of EuVECA[5] and EuSEF[6] and the MiFID services passport; [7] • Extend the scope of ESMA’s mandate to standardise the content and transmission of marketing notifications [8] to include the standardisation of updates to notifications that have been previously submitted; • Expand the proposed ESMA central database of funds and management companies [9] to act as a single central “hub” for notifications and fund documentation (e.g., KIIDs); • Remove the proposed conditions for management companies to discontinue marketing in a host Member State because these conditions do not enhance investor protections afforded by existing obligations and may create unfairness between exiting and remaining fund investors. [10] As noted by the Regulatory Scrutiny Board, [11] we recommend that the Commission continue to examine factors that affect cross-border distribution not covered by the initiative, including other impediments and barriers (e.g. tax and administrative arrangements) to the offering of funds and detract from the attractiveness of cross-border investment. [1] ICI Global carries out the international work of the Investment Company Institute, the leading association representing regulated funds globally. ICI’s membership includes regulated funds publicly offered to investors in jurisdictions worldwide, with total assets of US$29.2 trillion. ICI seeks to encourage adherence to high ethical standards, promote public understanding, and otherwise advance the interests of regulated investment funds, their managers, and investors. ICI Global has offices in London, Hong Kong, and Washington, DC. [2] Proposal for a regulation on facilitating cross-border distribution of collective investment funds and amending Regulations (EU) No 345/2013 and (EU) No 346/2013 and Proposal for a directive amending Directive 2009/65/EC and Directive 2011/61/EU with regard to cross-border distribution of collective investment funds [3] Local facilities to perform the tasks specified in the revised Article 92 to the UCITS Directive (2009/65/EC). [4] Building on the proposals in Article 11 of proposed Regulation to standardise notifications. [5] New Article 14a(7) to the EuVECA Regulation [6] New Article 15a(7) to the EuSEF Regulation [7] Article 34, MIFID II and Article 92, MIFID in respect of the provision of certain investment services by AIFMs. [8] Article 11, proposed Regulation. [9] Article 10, proposed Regulation. [10] Proposed new Article 83a to the UCITS Directive contained in Article 1(7), proposed Directive [11] Opinion of the Regulatory Scrutiny Board SEC(2018)129 final.
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Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

26 Feb 2018 · Regulation of investment funds: cross-border distribution, PEPP, prudential regime for investment firms

Response to Review of the European Supervisory Authorities

23 Jan 2018

ICI Global is deeply concerned that Article 31a on third-country delegation in the European Commission’s (Commission) proposed reforms of the European Supervisory Authorities (ESAs) will detrimentally affect the prominence of UCITS as global investment vehicles. Many of our members manage and sponsor regulated funds domiciled in multiple jurisdictions (including UCITS) and have global business operations that provide services to those funds. The Commission’s proposed Article 31a has the potential to affect directly these firms that currently service UCITS worldwide for the benefit of EU and global investors. The Commission’s proposal would enable the European Securities and Markets Authority (ESMA) to review and potentially override Member States’ authorisation of a UCITS fund manager that delegates a material part of its activities to delegates in non-EU countries while maintaining the status quo for authorisation of delegation to other EU Member States. This bifurcated approach—which calls into question delegation outside the European Union—risks raising costs to UCITS investors by imposing unnecessary requirements and possibly severely limiting the efficient delegation of asset management functions outside the European Union. Article 31a therefore has the potential to result in significantly negative consequences for UCITS and their investors. As explained in the attached position paper, we believe EU policymakers should not adopt Article 31a for the following reasons: • Delegation enables asset managers to bring efficiency and expertise to the operation of UCITS for the benefit of fund investors by enabling these funds to access investment expertise around the globe in a cost-effective manner. The UCITS Directive recognizes the benefits of delegation and provides strong oversight over this practice to protect investors. • The proposed new provision on delegation does not add any benefits to the existing UCITS framework because ESMA already has all the authority it needs to harmonize standards for delegation. The Commission also fails to articulate a rationale for disparate treatment of third-country delegation and takes ESMA on a needless detour rather than encouraging ESMA to focus its existing powers and resources to tackle challenges that have already been identified, such as cross-border distribution of UCITS. • A change to the current process for approving delegation and potentially limiting a management company’s ability to delegate portfolio management outside of the European Union could increase investor costs, lessen the quality of the investment expertise, and/or limit UCITS offerings. These negative consequences could lead investors to forego UCITS and instead look to other types of collective investment vehicles or products to meet their investment needs. Given the phenomenal success of UCITS and the regulatory framework, we caution EU policymakers against disturbing the appropriate balance of regulation and flexibility that has served EU and global investors so well for over three decades.
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Response to Reducing barriers to cross-border distribution of investment funds

20 Jul 2017

ICI Global welcomes the opportunity to respond to the European Commission’s (“the Commission”) Inception Impact Assessment on reducing barriers to the cross-border distribution of investment funds. From the outset, ICI Global has strongly supported the Commission’s efforts to make it easier to distribute and invest in UCITS and AIFs on a cross-border basis, thereby contributing to the Commission’s goal of creating deeper, more liquid European capital markets for the benefit of businesses and investors across the region. ICI Global has provided detailed comments to the Commission concerning cross-border fund distribution in its submissions to the: (i) Commission’s cross-border distribution consultation; (ii) CMU Mid-Term Review; (iii) Retail Financial Services Green Paper; and (iv) consultation on the European Supervisory Authorities. In our supporting document, we have provided our assessment of the qualitative and quantitative impact on cross-border fund distribution arising from EU and Member State regulatory requirements in four areas covered by the Inception Impact Assessment, as summarised below: * Administrative Requirements - Our analysis suggests that the appointment process for a single paying agent can take on average between 4-6 weeks – with many of our members saying it takes at least 4 weeks – and for multiple paying agents the process can take several months. Our analysis also suggests that the cost of appointment varies considerably across Member States and different paying agents, with estimated costs ranging from a few thousand Euros to tens of thousands of Euros per year per paying agent. * Cross-border Marketing Notifications - Our analysis suggests that the cost of host Member State procedures can often run to tens of thousands of Euros, particularly for marketing notifications concerning retail distribution. Notification procedures often take at least 4-6 weeks to complete for retail distribution notifications, and at least 3 weeks for institutional distribution notifications. *Local Marketing Requirements - Our analysis shows that to meet these requirements funds typically incur legal counsel fees, vendor customization costs and website development costs that typically run to tens of thousands of Euros each year. * Online distribution - Our analysis shows one qualitative impact of this divergence is the opportunity cost for an investor whom would have otherwise been able to access information and invest in a fund, but is unable to do so due to regulatory hurdles or barriers in his/her country. In conclusion, we believe that the Commission’s inception impact assessment addresses the main issues concerning the cross-border distribution of UCITS and AIFs. The examples and estimates contained in this response, supplement our prior submissions and further highlight the monetary, time and opportunity costs implications of these issues with negative consequences for fund investors, in particular EU citizens saving for their long-term or retirement needs.
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Response to EMIR Amendment

18 Jul 2017

Please see attached letter.
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Meeting with Tatyana Panova (Cabinet of Vice-President Valdis Dombrovskis)

9 Jun 2017 · CMU; Long Term Investments

Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

8 Jun 2017 · European Capital Markets

Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union)

7 Jun 2017 · Investments in Europe

Meeting with Tatyana Panova (Cabinet of Vice-President Valdis Dombrovskis)

22 Mar 2017 · Fund Distribution, PEPP

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

29 Nov 2016 · financial services agenda

Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union)

14 Nov 2016 · US election and its geopolitical consequences, relationship between EU and USA, global investment funds

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

20 Oct 2016 · Commission’s PEPP consultation

Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

19 Oct 2016 · PEPP initiative

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

12 Oct 2015 · Markets in Financial Instruments Directive II

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

17 Mar 2015 · Capital Markets Union