Position paper - Trilogue recommendations for Central Securities Depository Regulation (CSDR) Markets in Financial Instruments Regulation (MiFIR) Alternative Investment Fund Managers Directive (AIFMD)

The EU co-legislators are currently negotiating the review of Central Securities Depository Regulation (CSDR), Markets in Financial Instruments Regulation (MiFIR) and Alternative Investment Fund Managers Directive (AIFMD). These files are essential for functioning of the European Capital Markets Union (CMU). Despite many positive aspects, businesses have identified areas for refinement that would further ensure strong and attractive European capital markets. Amongst others, co-legislators should focus on:

• Narrowing of the mandatory buy-in (MBI) provisions and digitising post-trade processes with regard to the CSDR.
• Creating a consolidated tape and calibrating transparency regimes within the MiFIR.
• Ensuring that liquidity risk management is the primary responsibility of the investment manager and opting for qualitative reporting with regard to the AIFMD.