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AMIC Responses to consultations
 
24 October 2016
On 24 October 2016, ICMA's AMIC has 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 [link available here] 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 [link to response here] to the Consultation Document on an EU framework for simple, transparent and standardised securitisation.

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

14 January 2015
AMIC joint response [link to response here] 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 [link to response here] 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 (currently dormant) common response [link from here] to the EIOPA Consultation paper on the proposal for Quantitative Reporting Template for Financial Stability Purposes.  

20 January 2012
The Solvency II Working Group (currently dormant) common response [link from here] to EIOPA consultation paper on reporting issues.
2011

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.


2010

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.


2009

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