Bridge over ocean
1 November 2019 Position Paper

CFA Institute Blueprint for the EU Capital Markets Union for the European Parliamentary Legislative Period, 2019–2024

  1. Josina Kamerling
  2. Roberto Silvestri
  3. Olivier Fines, CFA
  4. Sviatoslav Rosov, PhD, CFA
  5. Kazim Razvi, FCCA

An overview of issues facing 2019-2024 European Union policymakers tied to CFA Institute recommendations and research.

This blueprint addresses four principal topics: capital markets union, fintech, sustainable finance, and value for money. These four themes are priorities for CFA Institute members and also represent the areas in which our policy experts are most involved and engaged. We remain at the disposal of the European Commission and other institutions that wish to discuss these matters and our recommendations further.
CFA Institute Blueprint for the EU Capital Markets Union for the European Parliamentary Legislative Period, 2019–2024 View the full article (PDF)

Capital Markets Union

The main opportunities for the capital markets union (CMU) initiative are centered around: small and midsize enterprise financing; making public markets more attractive; cross-border retail markets; and systemic risks stemming from the asset management sector.

Our Position

  • Focus on policies and incentives and products that will encourage long-term investments by savers.
  • Focus policies on the mechanisms that could be necessary to ensure an efficient market for independent research.
  • Monitor the impact of regulatory measures on smaller firms.
  • Continue to set a clear focus on investor protection by enhancing standardized disclosure requirements.
  • Consider the appropriate mechanism required to grant the European Securities and Markets Authority more direct supervisory powers over practices and rules pertaining to cross-border distribution of investment funds.


The main issues for fintech are an increased likelihood of flows resulting from automated financial advice, crating behavioral biases in clients; and lack of regulation for crypto assets, leading to market manipulation and inefficiency.

Our Position

  • Introduce a European framework for crowdfunding and peer-to-peer lending.
  • Facilitate and support creation of innovation resources and intermediaries for start-ups looking to use financial technology for capital raising.
  • Evaluate the need to regulate crypto assets and further the discussion as to whether they constitute financial instruments.

Sustainable Finance

The main issues for sustainable finance are the lack of agreed-on definitions; dissimilar training for investors; lack of quality and comparability of ESG data; the voice of the minority shareholders; variable regulatory and legislative approached for dealing with integration of ESG issues in investment analysis and decisions.

Our position

  • We advocate for strong standards on how investors should include governance issues in investment analysis.
  • We encourage promotion of greater board accountability to minority shareholder and discourage the practice of differential ownership.
  • We support the work done by the European Commission’s Technical Expert Group and its technical report on EU taxonomy.

Value for Money

The main issues for retail investors are these: there remains insufficient understanding of how investment products are sold and fees paid; exclusion of the presentation of past performance information; PRIIPs (Packaged retail investment and insurance products) regulation regarding its scope of application remains unclear.

There is one main issue for institutional investors: MiFID II rules may have unexpected negative impact on the quality and coverage of research.

Our position

  • Enhance consistency of definitions and rules.
  • Focus policies on the quality and meaningfulness of the information received by investors.
  • Look closer at potential unintended impacts of MiFID II rules.
  • Clarify the scope of application of the PRIIPs Regulation.

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