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AMIC responses to consultations
AMIC responds to IOSCO consultation on leverage in investment funds

On 1 February 2019 AMIC published a response to a consultation report by the International Organization of Securities Commissions (IOSCO) on leverage in investment funds. In its response, AMIC welcomes the focus by IOSCO on each fund level on the potentially risky activities of asset managers as compared to an approach at management company level. Furthermore, AMIC agrees with IOSCO’s proposed two-step approach to measuring risk associated with leverage. With regard to the first step, AMIC recommends that the gross notional exposure (GNE) figure is combined with the net notional exposure (NNE) figure to filter potentially risky funds. AMIC views the second step as a framework for a more detailed risk-based analysis of risk in each jurisdiction, recognising that leverage as a concept is not synonymous with risk.
AMIC publishes position on ESRB review

On 16 May, AMIC issued a position paper on the on-going review of the European Systemic Risk Board (ESRB). In light of the recent Recommendation on liquidity and leverage risks in investment funds (ESRB/2017/6), we believe that ESRB’s governance could be improved. AMIC believes that the lack of public consultation, the intrusion by macro-risk supervision into the field of micro-regulation, and the unbalanced composition of the board of the ESRB justifies that the ESRB review includes an improvement of the functioning and composition of the ESRB. AMIC lays out two targeted changes to the ESRB review proposal to balance the composition of the ESRB to ensure greater representation from securities markets and to ensure consultation with industry takes place where legislative change is recommended.

AMIC responds to FRC consultation on corporate governance and stewardship

On 28 February, AMIC responded to a consultation by the UK Financial Reporting Council (FRC) on the review of the UK Corporate Governance Code and on the UK Stewardship Code. The AMIC response calls for an enhanced role for bond holders in corporate engagement with stakeholders but recommends that the comply and explain approach is retained as a flexible way for companies and investors to adhere to the Code. AMIC looks forward to continued engagement with the FRC, in particular when a more thorough review of the Stewardship Code is launched later this year.

AMIC publishes statement with regard to consultation on sustainable finance

On 22 January, AMIC issued a brief statement in response to a consultation by the European Commission on investor duties and asset managers’ duties regarding sustainability. The AMIC statement is limited to the potential legislative consequences of the initiative to clarify investor duties, subject to specific recommendations in the Final Report of the High-Level Expert Group on Sustainable Finance.

AMIC responds to publication of the ESAs Review

On 23 January, AMIC published its response to the publication of the proposals to review the European Supervisory Authorities (ESAs) and the European Systemic Risk Board (ESRB).

AMIC welcomes many of the very positive aspects of the proposals. ICMA and AMIC are strong supporters of Capital Markets Union (CMU) and we welcome proposals which will help to deliver better functioning capital markets for investors, including in the areas of: (1) enhanced supervisory convergence; (2) inclusion of ESG factors; (3) cost-benefit analyses for guidance and recommendations; (4) improved third country equivalence; and (5) role for ESMA in data collection.

Nevertheless, AMIC also has some significant concern with several elements of the texts. These proposals should be revisited if this framework is to be successful in increasing supervisory convergence and addressing the challenge of the UK leaving the EU. Our significant concerns, which we will outline in greater detail in our response, are in the areas of: (1) direct supervision of funds; (2) ESMA opinions on delegation arrangements; (3) funding arrangements; (4) consultations on Q&As; and (5) organisation of the ESRB.
AMIC responds to IOSCO consultations on investment fund liquidity risk management

On 18 September AMIC responded to IOSCO’s consultations on (1) CIS Liquidity Risk Management Recommendations and (2) Report on Open-ended Fund Liquidity and Risk Management – Good Practices and Issues for Consideration.

AMIC broadly agrees with the suggested amendments to IOSCO’s 2013 liquidity risk management recommendations. However, AMIC suggests some amendments to the recommendations to bring them in line with current market practice. Furthermore, AMIC counsels caution on stress tests, which can be misleading particularly on a systemic level. AMIC also welcomes the report on best practices on fund liquidity risk management, which helpfully references AMIC’s joint report with EFAMA on liquidity risk management.

The responses can be found here:
(1) AMIC response to IOSCO Consultation on CIS Liquidity Risk Management Recommendations
(2) AMIC response to IOSCO Consultation Report on Open-ended Fund Liquidity and Risk Management – Good Practices and Issues for Consideration

AMIC responds to Central Bank of Ireland consultation on ETFs

15 August
ICMA's AMIC has submitted a response to the Central Bank of Ireland’s Discussion Paper on Exchange Traded Funds (ETFs). AMIC has long taken an interest in the development of ETFs. AMIC has long taken an interest in the development of ETFs. In 2011 AMIC published a short general paper on ETFs with a description of different types of ETFs, the state of the ETF market, assessments of market trends in ETF development and usage, the future development of the ETF market and the value of the ETF brand. More recently, AMIC’s interest in ETFs is limited to their relevance to the debate on systemic risk. We have already been active in the global debate on the possible systemic risk related to asset managers.
The AMIC response on ETFs addresses certain topics in the consultation, in particular potential systemic risks in ETFs and the impact of ETFs on corporate bond liquidity.
To view the response, click here.
24 October 2016
On 24 October 2016, ICMA's AMIC submitted its response to the European Commission's consultation paper on whether the existing EU macro-prudential framework is functioning optimally. AMIC raised concern about expanding the mandate and powers of the European Systemic Risk Board (ESRB) to non-banking under the current governance framework of the ESRB. AMIC recommends much greater integration of securities markets supervisory expertise in the macro-prudential policy framework. AMIC also suggests that already reported data is better used to understand financial markets from a holistic perspective.

3 October 2016 
ICMA is conducting a consultation on the new London Term Sheet of GDP-Linked Bonds with interested members of ICMA’s Asset Management and Investors Council. Click here for more information.

21 September 2016
ICMA’s AMIC has submitted its response to the Financial Stability Board’s (FSB) consultation paper on proposed policy recommendations to address structural vulnerabilities for asset management activities.
AMIC welcomed the FSB’s focus on activities instead of designating individual companies as systemically risky. However, AMIC cautions against returning to the designation debate. AMIC also encourages the FSB to consider a wider group of market participants than simply asset managers when assessing risk and formulating policy recommendations. AMIC also notes that any effort to harmonise leverage calculation should not impact the existing methods to calculate fund leverage established through European legislation.
To view the document, click here.

7 September 2016 
The ICMA AMIC Bail-in Working Group has sent a discussion letter to the ECB. The letter highlights observations on the operation of the bail-in regime, from the buy-side point of view, and builds upon, and reflects evolutions in thinking since, a letter sent to the ECB on 31 July 2015, also on the bail-in mechanism.
To view the discussion letter, click here.

23 May 2016 
In the absence thus far of enhanced rules on mandatory pool disclosure on a Europe wide basis from the European Commission, industry led initiatives are essential to the continued good operation and standing of the covered bond market. The ICMA AMIC Covered Bond Investor Council welcomes the fact that the Harmonised Transparency Template (HTT) is to be reviewed and enhanced on a regular basis and are taking the opportunity of this review to comment on its effective implementation to date and to provide comments from members on possible features to consider as part of the review process.
The CBIC response is based on the information available on the Covered Bond Label website as well as issuers’ website. In addition, we reviewed the various responses the CBIC has written over the years regarding enhancing transparency in the covered bond market.
To view the response, click here.

18 April 2016
The International Capital Market Association’s (ICMA) Asset Management and Investors Council (AMIC) and the European Fund and Asset Management Association (EFAMA) have published today a report on the legislative requirements and market-based tools available to manage liquidity risk in investment funds in Europe. The report also offers some recommendations to further improve the general liquidity management environment.
To view the press release, click here.
To view the report, click here.
To view an executive summary, click here.

3 March 2016
Four leading European trade associations representing investors, issuers and other market participants came together to support the new framework for securitisation regulation - a robust and successful framework for simple, transparent and standardised (STS) securitisation.

6 January 2016
The ICMA AMIC Covered Bond Investors Council (CBIC) has responded to the European Commission’s consultation on Covered bonds in the European Union. The consultation was launched on 30 September 2015. The CBIC noted the underlying assumption in the economic analysis that the extreme convergence of covered bond spreads before the crisis should be the norm and that subsequent events point to a sub-optimal fragmentation of markets within the European Union. However, CBIC members argued that markets prior to 2007 had mispriced risks inherent in the securities and that a return to that condition was not necessarily a desirable outcome. Particularly in the absence of implicit state support for the banking system, different covered bonds do reflect different underlying risk characteristics and it is the job of the market to identify and price these risks appropriately.
With regard to the main question in the consultation, the two options for covered bond harmonisation, the CBIC noted that there was insufficient detail in the consultation to give a definitive view. Some CBIC members believed that voluntary convergence of national regimes would suffice, particularly if backed by measures like capital requirements referencing the best practice guidelines. Other CBIC members expressed a preference for an EU legal framework with minimum standards based on current best practice.
To view the response, click here.
31 July 2015
ICMA Bail-In Working Group discussion letter to the ECB, the purpose of which is to set out views on the operation of the bail-in mechanism.

13 August 2015
AMIC response to the European Commission’s consultation on the review of the European Market Infrastructure Regulation (EMIR).

29 May 2015
AMIC’s Market Finance Working Group (formed in December 2014 to address industry concerns about regulatory focus on shadow banking) response to a second FSB/IOSCO consultation on a methodology to identify NBNI G-SIFIs.

13 May 2015
AMIC response to the Consultation Document on an EU framework for simple, transparent and standardised securitisation.

13 February 2015
AMIC joint response to the BCBS IOSCO Consultative Document on Criteria for identifying simple, transparent and comparable securitisations.

14 January 2015
AMIC joint response to the EBA’s Discussion Paper on simple standard and transparent securitisations. 
10 October 2014
AMIC response to the FCA Discussion Paper DP14/3 – the use of dealing commission regime

12 September 2014
ICMA Bail-in Working Group response to the questions enumerated in the Financial Policy Committee’s Review of the Leverage Ratio.

5 September 2014
AMIC response to the IOSCO consultation paper on Good Practices on Reducing Reliance on CRAs in asset management.

21 August 2014
ICMA AMIC Covered Bond Investor Council report on cover pool data disclosure, calling for further disclosure of cover pool data. To view the ICMA Transparency report click here. To view the press release, click here.

18 August 2014
ICMA CBIC response to the Consultation Paper launched by the European Securities and Markets Authority (ESMA) on 11 July 2014 on the Clearing Obligation under Regulation (EU) No 648/2012, which outlines the framework of the European Market Infrastructure Regulation (EMIR). To view the response click here.

7 April 2014
 AMIC response to the FSB/IOSCO consultation on the assessment methodologies for identifying non-bank non-insurer Global Systematically Important Financial Institutions (‘NBNI G-SIFIs’).

7 March 2014
ICMA CBIC statement welcoming the infrastructure the Covered Bond Label has put in place for further strengthening of the European covered bond market, and noting the improvement in the minimum transparency requirement. To view the statement click here

25 February 2014
AMIC response to FCA Consultation CP13/17 – the use of dealing commission rules.

31 January 2014
AMIC response to ESMA consultation paper on Revision of the provisions on diversification of collateral in ESMA’s guidelines on ETFs and other UCITS.

20 December 2013
AMIC response to the Public Consultation on Best Practice Principles for Governance Research Providers

17 December 2013
ICMA CBIC statement in support of the inclusion of covered bonds as extremely high liquid assets under the Liquidity Coverage Ratio (LCR) within the new liquidity provisions for the European banking sector. To view the statement click here.

21 October 2013
ICMA CBIC letter in response to Moody’s request for comments: "Approach to Determining the Issuer Anchor Point for Covered Bonds". To view the response, click here.

7 August 2013
ICMA CBIC statement regarding covered bond rating agencies based on discussions within its membership.

14 January 2013
AMIC response to the FSB consultation papers regarding ‘strengthening oversight and regulation of shadow banking’. 


18 October 2012
AMIC response to the European Commission public consultation entitled "UCITS Product Rules, Liquidity Management, Depositary, Money Market Funds, Long-Term Investments on a number of regulatory issues related to money market funds, eligible assets, the use of derivatives, and depositary passports".

28 September 2012
AMIC response to the BCBS and IOSCO consultative paper ‘Margin Requirements for non‐centrally‐cleared derivatives’

25 September 2012
AMIC response to ESMA Consultation Paper on recallability of repo and reverse repo arrangements

15 June 2012
AMIC response to the European Commission Green Paper on shadow banking.

30 March 2012
AMIC response to ESMA Consultation paper on guidelines on ETFs and other UCITS issues.

20 February 2012
The Solvency II Working Group common response to the EIOPA Consultation paper on the proposal for Quantitative Reporting Template for Financial Stability Purposes.  

20 January 2012
The Solvency II Working Group common response to EIOPA consultation paper on reporting issues.


CBIC European transparency standards
A public consultation on the ICMA CBIC transparency template was launched on 14 April 2011, all documents are available here.
More information about the second round of consultation is available here.
The final template is available here.  

22 September 2011
AMIC response to ESMA on discussion paper on its policy orientations on guidelines for UCITS Exchange-Traded Funds and Structured UCITS.

18 November 2011
AMIC response to the Kay Review of UK Equity Markets and Long-Term Decision-Making.

22 July 2011
AMIC response to the European Commission Green Paper entitled ‘The EU corporate governance framework’.

16 May 2011
AMIC response the FSB note entitled Potential financial stability issues arising from recent trends in Exchange-Traded Funds (ETFs).

17 January 2011
AMIC statement supporting the FRC Stewardship.

17 January 2011
AMIC response to the UK Department for Business, Innovation and Skill Call for Evidence – A long‐term focus on Corporate Britain.  

14 January 2011
AMIC general comments on the AIFMD implementing measures published in CESR Call for Evidence on the AIFMD.

6 January 2011
AMIC response to the European Commission consultation on the issue of overreliance on CRAs.


4 November 2010
AMIC response to IOSCO Consultation Report on Intermediary Internal Controls Associated with Price Verification of Structured Finance Products and Regulatory Approaches to Liquidity Risk Management.  
8 October 2010
AMIC response to FSA Consultation Paper – CP 10/19 – Revising the Remuneration Code.

16 August 2010
AMIC response to European Commission Green Paper – Corporate governance in financial institutions and remuneration policies.

21 January 2010
CBIC statement on the on-going usage of ‘shadow / IOI’ books.


5 February 2009
AMIC response to the European Commission Services consultation paper on hedge funds.