Memo #
32850

ICI Global Submits Response to ESAs' Survey on Environmental/and or Social Financial Product Templates

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[32850]

October 20, 2020 TO: ICI Global Members
ESG Task Force (Global)
EU ESG Disclosure Regulation Working Group
EU Sustainable Finance Strategy Working Group
Global Advocacy Coordination Advisory Committee
ICI Global Regulated Funds Committee SUBJECTS: ESG
International/Global RE: ICI Global Submits Response to ESAs' Survey on Environmental/and or Social Financial Product Templates

 

We filed the attached response on Friday, 16 October, making the following high-level points:

  • Proposed templates illustrate the over-detailed nature of the proposal for the regulatory technical standards under the Sustainable Finance Disclosure Regulation (SFDR).  We re-emphasised the key theme from our SFDR RTS Response on the product-level disclosure.[1]  The ESAs must streamline pre-contractual disclosures to make them meaningful to end investors, i.e., they must focus on information that will help investors make investment decisions, while reserving technical details for a website, non-prospectus disclosure.  
  • The ESAs must allow for flexibility in incorporating the SFDR disclosures into the regulatory documents (UCITS prospectus and annual report)  –  to be included in the regulatory documents themselves or via a separate document incorporated by reference.
  • We also included a number of specific technical comments on the templates in Question 6.

Thank you again to everyone for your thoughtful feedback. 

 

Anna Driggs
Director and Associate Chief Counsel
ICI Global

 

Attachment

endnotes

[1] See Memorandum No. 32734, dated September 2, 2020  available at: https://www.iciglobal.org/iciglobal/pubs/memos/memo32734.