The Fund Regulation & Investment Services Committee (FRIS) deals with "core" laws and regulations surrounding investment funds and manager (investment) services. Topics include AIFMD/UCITS, retail investing, market infrastructure, operational resilience, prudential requirements and anti-money laundering.
President
Judith Boom
Senior Legal Counsel at APG Asset Management
From DUFAS, we welcome the European Commission's Market Integration and Supervision Package (MISP) as an important step towards a better functioning and more integrated European capital market. The package fits within the broader ambition to strengthen savings and investment in Europe and to allow private capital flows to better contribute to economic growth, innovation and strategic investments. For asset managers operating in multiple European member states, further market integration is of great importance. Although the industry formally operates within one single market, in practice managers still experience significant differences in national regulations, supervisory practices and administrative processes. This fragmentation leads to higher costs, longer lead times and unnecessary complexity. The MISP contains proposals that seek to remove these obstacles in a targeted way.
In April, the Ministry of Finance published the Consultation on Implementation of the Amended AIFM and UCITS Directive Act. DUFAS responded to this consultation. In our response, we have drawn attention to a number of clarifications and recommendations to align the implementation as closely as possible with the text of the European directives, the existing Dutch legislative framework and market practice.
In March, De Nederlandsche Bank (DNB) published a consultation on the Policy Rule on the Application of SREP Guidelines to Managers. This policy rule clarifies how DNB applies the SREP (Supervisory Review and Evaluation Process) guidelines to managers. In the Netherlands, not only investment firms but also managers of investment institutions providing MiFID services fall under the IFR/IFD regime. Based on national legislation, these managers are therefore subject to the ICARAP requirement, which authorizes DNB to apply SREP. From DUFAS, we have submitted a response to this consultation, sharing our concerns about the impact of this supervisory regime on Dutch managers.
The expert group falls under the Fund Regulation & Investment Services Committee, and monitors developments around the Alternative Investment Fund Managers Directive (AIFMD).
Daan Zebel
Preventing money laundering is also of great importance to asset managers. This expert group closely follows developments around Anti Money Laundering (AML), such as the impact of the new European AML package. The expert group falls under the Fund Regulation & Investment Services Committee.
Manouk Fles
The Digital Innovation & Resilience Expert Group focuses on digitalization in the asset management industry, including digital innovations such as AI, data & analytics, blockchain, cloud IT architecture, SaaS and regtech, as well as digital resilience, including DORA, the AI Act, NIS2, cybersecurity, continuity & recovery and third-party risk management.
Manouk Fles
This expert group deals with various topics around market infrastructure, as relevant to fund managers. These include MiFIR, EMIR and CSDR. The expert group falls under the Fund Regulation & Investment Services Committee.
Daan Zebel
Pension funds often outsource the management of their investments to specialized asset managers. Within this expert group we discuss developments in pension legislation and the possible impact on asset managers. The expert group falls under the Fund Regulation & Investment Services Committee.
Marlon Jansen
This expert group falls under the Fund Regulation & Investment Services Committee and focuses on prudential regulations applicable to asset managers.
Manouk Fles
This expert group deals with developments surrounding retail investors and falls under the Fund Regulation & Investment Services Committee. Important areas of focus are the Retail Investment Strategy and developments in the Savings & Investment Union to promote retail participation.
Manouk Fles
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