At the request of the European Supervisory Authorities, which are seeking evidence ahead of the upcoming review of the KID-PRIIPS framework, this response calls for specific changes to the scope of application of the Key Information Document (the "KID"), including, for example, the definition of what is considered “made available”.
In this response we call for adjustments to the EU State Aid Framework. We highlight concerns with the existing definitions of undertakings in difficulty and small and medium enterprises - which do not reflect specificities of private equity and venture capital backed businesses. We also call for specific adjustments to the risk finance aid framework.
Invest Europe CEO, Eric de Montgolfier, was a key guest at the Annual Conference of the European Capital Markets Institute on December 2nd, 2021. During the event, entitled “Private equity and the Capital Markets Union”, he spoke about the crucial role our industry plays in supporting European businesses, describing how EU regulation can help private equity support the twin digital and green transition. His intervention focused on the different legislative initiatives the European Commission could take to incentivise private capital, from the review of the AIFMD fund marketing passport to changes to be brought to the prudential legislation covering institutional investors such as insurers (Solvency II) and banks (CRR). He also called for a review of the MiFID investor categorisation rules and welcomed the review of the voluntary ELTIF passport aimed at opening the market to some types of retail investors.
In this speech Invest Europe CEO Eric de Montgolfier described which changes to the Capital Requirements framework are warranted to ensure that banks are allowed to invest into long-term and diversified funds such as private equity
In this new letter to the European Commission, Invest Europe expresses its concerns about the Final Report on SFDR from the European Supervisory Authorities (ESAs). In particular, we refer to the significant new legal risk that certain of the ESAs’ changes create for closed-end funds and ask the Commission to address this before putting forward its legislative proposal to the co-legislators.
12 associations, including Invest Europe, have jointly written to the European Commission expressing their views on the planned initiative to fight the use of shell entities.
Invest Europe, as pan-European representative of the private equity and venture capital industry, commits to actively contribute to the EU becoming climate-neutral by 2050, as set out in the European Green Deal.
We support initiatives to decrease cross-border tax frictions, simplify processes and close abusive practices. However, relevant exemptions must be preserved, in order to ensure tax neutrality of funds.
The long-term equity (LTE) category (Article 171a of Solvency II Delegated Acts) is particularly relevant for exposures to private equity and venture capital funds. As the Solvency II Directive only looks at the equity risk from a volatility angle, this position paper explains why this category is an essential element of the framework and how to make existing criteria more workable.
In this letter Invest Europe congratulates the EBA on its suggestion to only include as shadow banking entities managers of funds that are substantially leveraged - but notes that the EBA's definition of shadow banking entities remains too broad and risks capturing entities that are creating little risk.
Martin Bresson
Public Affairs Director
Erika Blanckaert
Senior Public Affairs Manager
Xandra Hjort
Public Affairs Officer
Sofia Garrido Perez
Public Affairs Officer
Christophe Verboomen
Public Affairs Manager
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