Entry into application
As our feature article shows (p 2), implementing Europe’s new regime for investment firms, which comprises the Investment Firms Regulation (IFR) and the Investment Firms Directive (IFD), is a major project for AMAFI. The association is meeting regularly with the Treasury and the prudential regulator, ACPR, to discuss transposition of the IFD into French law and the practical arrangements required to switch investment firm classes to the new regime. While some operational solutions are now emerging, with just months to go until the 26 June 2021 deadline, concerns remain. Given that some answers can only come at European level, the new regime’s entry into application should be delayed by a few months.
In connection with the new regime, the European Banking Authority (EBA) is consulting on guidelines for sound remuneration policies for Class 2 investment firms.
Since the proposed guidelines are closely modelled on those put forward in connection with the fifth Capital Requirements Directive, on which EBA also consulted recently, AMAFI partly based its response (AMAFI / 21-19) on the feedback it submitted in January (AMAFI / 21-07). Among the top priorities are Brexit-related implications for competitiveness and the capacity of EU participants to attract talent. In terms of the proposals for gender-neutral pay policies, AMAFI argued that EBA had overstepped its mandate in areas linked to gender neutrality, such as access to training and internal mobility. Pointing to IFD’s sector-specific focus, the association said that the guidelines were not an appropriate vehicle for dealing with these questions.