Article summary
The International Swaps and Derivatives Association (ISDA) and the Association for Financial Markets in Europe (AFME) have jointly responded to the European Commission’s consultation on the delegated acts under Directive 2014/65/EU, the Markets in Financial Instruments Directive. The changes concern the suitability requirements and the integration of ‘sustainability risks across product governance, operating conditions, risk management and organisational requirements’. The ISDA and the AFME recommends that the Commission provide 'an appropriately staggered timetable' to implement the delegated acts. The associations have also highlighted that the ‘availability of relevant and reliable environment, social and governance (ESG) data from issuers remains a significant issue’ and it ‘will impede the process of identifying to what extent a product meets a client’s sustainability preferences’.
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