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Positions

November 2023

The Swiss Finance Council believe that FIDA has the potential to unlock data sharing between wealth management firms, WealthTech firms and other service providers within the EU. 

However, it is key that FIDA ensures a fair and secure data ecosystem that adds value to consumers and end users. We welcome that the management of the access to customer data will be left to market actors through the setting-up of financial data sharing schemes, while ensuring financial incentives and a level playing field for data holders.

We welcome a clarification of the scope of the proposed mandatory customer data access rights, and in particular support limiting the access rights to retail and SME customer categories and corresponding data. A staggered approach to the introduction of client types for data sharing would also allow to manage implementation costs and focus on key use cases first. 

More broadly, we would support the adoption of a gradual approach to development of data sharing schemes based on customer demand. A focus on real added value use cases would reduce the significant implementation costs for data holders, as they will not be compensated for building the necessary technical infrastructure, modalities and standards to share their data with data users when there is no real demand by customers.

Finally, we would support minimum API standards and security requirements to help open finance scale. We also support the introduction of a clear and fair liability regime, which would provide guarantee legal certainty and help gain trust of customers to share their data with financial information service providers

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All other Positions

December 2024

The EU securitisation market remains underdeveloped, limiting investment opportunities in EU financial instrument and constraining banks' ability to manage their balance sheets. The Swiss Finance Council (SFC) therefore supports the European Commission's intention to improve the functioning of the EU securitisation framework. In its response to the European Commissions’ consultation, the SFC emphasizes the need to adjust the prudential treatment and move towards a more principles-based approach to disclosure in order to unlock the potential of securitisation as a powerful financing tool. 

November 2024

The SFC has responded to the European Commission’s targeted consultation on assessing the adequacy of macroprudential policies for non-bank financial intermediation (NBFI).

September 2024

The Swiss Finance Council has a strong interest in the targeted consultation on the effectiveness of the macroprudential framework for the Non-Bank Financial Intermediation (NBFI) sector. Swiss asset managers manufacture both Money Market Funds (MMFs) and Open-Ended Funds (OEFs) within the EU and manage and distribute them both within the EU and on a cross-border basis. Therefore, any changes to the EU macroprudential framework for MMFs and OEFs would have a direct impact on Swiss asset managers. More broadly, given the interconnectedness of EU and Swiss markets, there is need for continued international cooperation on the NBFI agenda.

June 2024

Given that the EU and Swiss economies are closely interconnected, we have a shared interest in ensuring the international competitiveness of the European economy. Our members are therefore deeply committed to the EU’s goal of building an effective and open Capital Markets Union that helps capital flow to EU projects and business that are key for the transition towards a more sustainable and digital economy.

April 2024

The Swiss Finance Council co-signed a response to the EBA’s Consultation on Draft Guidelines on the management of ESG risks under the Capital Requirements Directive (CRD 6)  

April 2024

Swiss Finance Council response to ESMA consultation on draft guidelines on reverse solicitation under MiCA  

January 2024

The Swiss Finance Council has a strong interest in the discussion on shortening the settlement cycle to T+1 across equities, fixed income and ETFs in Europe because Swiss, EU and UK securities markets are closely interconnected and in the post-trade area apply the same principles and technical standards. This is a complex area that will require careful analysis and policy development to assist firms in managing the significant operational challenges that will stem from the transition.

December 2023

The Swiss Finance Council has an interest in the SFDR because our members operate as retail investment product manufacturers, distributors, and advisors, serving EU clients from both within the EU and on a cross-border basis.  

December 2023

The Swiss Finance Council welcomes the public reflection on the future of the EU Capital Markets Union (CMU) project. We believe that a particular focus should be given on measures that can bring more size into the EU capital market in the short and medium term and guide financing of the green transition. 

September 2023

The Swiss Finance Council has an interest in the EU Retail Investment Strategy because our members operate as both retail investment product manufacturers and distributors, serving EU clients from both within the EU and on a cross-border basis.

Joint association letter on CSDDD and transition plans – September 2023

Swiss Finance Council’s comments on draft ESRS Delegated Act – July 2023

SFC Position on Instant Credit Transfers in Euro : Amending the SEPA Regulation – May 2023

Amendments to the Corporate Sustainability Due Diligence Directive (CSDDD) proposal – November 2022

Open Finance Framework in the EU: For a broad, competitive, attractive and fair approach to data sharingl – October 2022

Feedback on the proposed Corporate Sustainability Due Diligence Directive (CSDDD) – August 2022

Feedback on the proposed Corporate Sustainability Reporting Directive (CSRD) and related Article 8 Taxonomy disclosures - April 2022

CRD VI Commission proposal on Third Country Branches (TCB): Position on market access, booking, liquidity and authorisation requirements (Art 47 and 48 CRD VI) - April 2022

Feedback on the Publication of the European Commission's Draft Capital Requirements Directive VI (CRD VI) - March 2022

Corporate Sustainability Reporting Directive (CSRD) proposal - December 2021

Joint letter on the treatment of incoming third country branches - September 2021

European Commission consultation on the draft EU Taxonomy Article 8 Delegated Act - June 2021

European Commission Consultation on the Renewed Sustainable Finance Strategy - July 2020

Joint letter to Vice-President Dombrovskis: “Investment Firm Regulation – third country firm regime" - November 2018

Joint letter to EU Finance Ministers in response to the proposal for an EU Digital Services Tax - November 2018

Public consultation on Fintech: a more competitive and innovative European financial sector - June 2017

Call for evidence: EU regulatory framework for financial services - January 2016

SFC response to European Commission Consultation on the impact of CRR/CRD4 on bank lending

SFC response to European Commission Consultation on EMIR Review

SFC response to European Commission Green Paper on Capital Markets Union

SFC response to IOSCO Consultation on Cross-Border Regulation