Overhauling France's SRI Label
The presidency of the committee in charge of France's socially responsible investment (SRI) Label recently consulted on guidance related to the next evolution of the Label. AMAFI submitted a joint response with the French Banking Federation supporting the overall guidance and making a number of suggestions ((AMAFI / 22-61). The two associations argued that eligibility to the label should also benefit funds that comply with the FBF-AMAFI charter on synthetic hedging of ESG funds, granted they are aligned with the upcoming Label’s requirements.
AMAFI and the FBF also indicated the unsuitable choice of the SRI Label as a common socially responsible investment basis to all financial products and that it would be more appropriate to identify common ESG criteria, given the wide diversity of in-scope products.
Mapping sustainable finance
Several pieces of sustainable-finance legislation came into effect this summer, including the delegated regulations on taxonomy and the MiFID II ESG delegated regulation and directive. These legislative amendments made it necessary to modify AMAFI's mapping of sustainable finance (AMAFI / 22-53), which will continue to be updated regularly as new instruments are adopted.
MiFID II and ESG
AMAFI responded (AMAFI / 22-43) to the AMF's consultation on amendments to its General Regulation resulting from the impending entry into effect of new MiFID II sustainability requirements for the distribution of financial instruments. Consistent with previous calls to ensure that customers enjoy the same level of protection regardless of their provider, AMAFI insisted that the rules for financial advisers in this area should be worded identically to those applicable to ISPs.
AMAFI also reviewed the consultation carried out by the 2 Degrees Investing Initiative (2DII) on behalf of the Finance ClimAct consortium sponsored by the European Commission. The consultation covered the draft template for a MiFID suitability questionnaire on customer sustainability preferences. AMAFI expressed concern about the legal status of the questionnaire, which would supplement MiFID II requirements set at European level, but without following the same democratic process. It therefore called for the questionnaire to be considered only as a best practice (AMAFI / 22-42).
