Europaudvalget 2020-21
EUU Alm.del Bilag 284
Offentligt
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EUROPEAN COMMISSION
Directorate-General for Financial Stability, Financial Services and Capital Markets Union
CONSULTATION DOCUMENT
PUBLIC CONSULTATION ON THE REVIEW OF THE EUROPEAN LONG-
TERM INVESTMENT FUNDS (ELTIF) REGULATORY FRAMEWORK
Disclaimer
This document is a working document of the Commission services for consultation and
does not prejudge the final decision that the Commission may take.
The views reflected on this consultation paper provide an identification on the approach
the Commission services may take but do not constitute a final policy position or a formal
proposal by the European Commission.
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 EUU, Alm.del - 2020-21 - Bilag 284: Notat samt høringssvar vedr. Europæiske langsigtede investeringsfonde (ELTIF’ere)
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Interested parties are invited to provide feedback on the questions raised in this
consultation
by 19 January 2021
at the latest through the
online questionnaire
available
on the following webpage:
https://ec.europa.eu/info/publications/finance-consultations-2020-eltif-review_en
Views are welcome from anyone.
If you are representing Member States, national competent authorities and/or ESMA,
market participants, such as asset managers, investment firms, credit institutions, financial
intermediaries, stock exchanges, institutional and retail investors, consumer and investor
organisations, manufacturers and distributors of financial products and services, financial
and legal advisers or other services providers, as well as academics and policy think-tanks,
you are kindly requested to disclose your affiliation below.
We invite you to add any documents and/or data that you would deem useful to your replies
on this website. Please always use this questionnaire even if you would like to submit
additional documents.
Please explain your responses and, as far as possible, illustrate them with concrete
examples and substantiate them numerically with supporting data and empiric evidence.
Where appropriate, provide specific operational suggestions to questions raised. This will
allow further analytical elaboration.
You are not required to answer every questions and you may respond to only those
questions that you deem the most relevant.
Please note that in order to ensure a fair and transparent consultation process
only
responses received through the online questionnaire will be taken into account and
included in the report summarising the consultation submissions.
This consultation follows the standard rules of the European Commission for public
consultations. Responses will be published unless respondents indicate otherwise in the
online questionnaire.
Responses authorised for publication will be published online following the expiration of
the public consultation.
You are requested to read the
privacy statement attached to this consultation
for
information on how your personal data and contribution will be dealt with.
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 EUU, Alm.del - 2020-21 - Bilag 284: Notat samt høringssvar vedr. Europæiske langsigtede investeringsfonde (ELTIF’ere)
Consultation questions
C
HOOSE YOU QUESTIONNAIRE
Please indicate whether you wish to respond to the short version (6 questions) or full
version (42 questions) of the questionnaire.
The short version only covers the general aspects of the ELTIF regime.
The full version comprises 36 additional questions addressing more technical features.
Note that only the questions that are part of the short version are also available in French
and German.
☐
I want to respond only to the
short version of the questionnaire
(6 questions)
X
I want to respond to the
full version of the questionnaire
(42 questions)
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 EUU, Alm.del - 2020-21 - Bilag 284: Notat samt høringssvar vedr. Europæiske langsigtede investeringsfonde (ELTIF’ere)
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SHORT VERSION OF THE QUESTIONNAIRE
DK additionally responds to specifics questions 4 to 6 of the short version
of the questionnaire.
1.
I
NTRODUCTORY QUESTIONS
Question 4. Which provisions and requirements pertaining to the eligibility of investments
and investment assets set out in the ELTIF Regulation need to be updated to improve the
functioning of the ELTIF framework? Please rate as follows:
1
(no policy
action
needed)
2
(policy
action could
be
considered)
3
(policy
action
desirable)
4
(policy
action
needed)
5
(policy
action
very
strongly
needed)
Don't
know -
No
opinion -
Not
applicable
A minimum
size eligibility
requirement
for real assets
investments
X
 EUU, Alm.del - 2020-21 - Bilag 284: Notat samt høringssvar vedr. Europæiske langsigtede investeringsfonde (ELTIF’ere)
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A condition
for an
exposure to
real estate
through a
direct holding
or indirect
holding
through
qualifying
portfolio
undertakings
of individual
real assets
X
Limitation on
eligible
investment
assets to
ELTIFs,
EuVECAs
and EuSEFs
X
Inability to
invest in a
“financial
undertaking”
X
 EUU, Alm.del - 2020-21 - Bilag 284: Notat samt høringssvar vedr. Europæiske langsigtede investeringsfonde (ELTIF’ere)
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EUR 500
000 000
threshold for
investing in
listed issuers
X
Rules related
to
investments
in third-
country
undertakings
X
Other
conditions and
requirements
related to
eligible
investment
assets and
qualifying
portfolio
undertakings
X
 EUU, Alm.del - 2020-21 - Bilag 284: Notat samt høringssvar vedr. Europæiske langsigtede investeringsfonde (ELTIF’ere)
Please specify what are the other conditions and requirements related to eligible investment
assets and qualifying portfolio undertakings you refer to in your response to question 4:
Question 4.1 Please explain your position on your answer to question 4:
Question 5. Should any of the following provisions of the ELTIF legal framework be
amended, and if so how, to improve the participation and access of retail investors to
ELTIFs?
a)
Minimum entry ticket for retail investors and net worth requirements
□
Yes
☐
No
X
□
Don’t know / no opinion /
not relevant
Please explain your answer to question 5.a and your suggested approach if you responded
yes:
Denmark believes that the current regulation setting up minimum entry ticket for retail
investors and net worth requirements is appropriate. This ensures that only more financial
robust retail investors may invest due to the risk and illiquidity of the products.
b)
Suitability test
□
Yes
☐
No
X
□
Don’t know / no opinion / not
relevant
Please explain your answer to question 5.b and your suggested approach if you responded
yes:
c)
Withdrawal period of two weeks
□
Yes
□
No
☐
Don’t know / no opinion / not relevant
X
Please explain your answer to question 5.c and your suggested approach if you responded
yes:
d)
Possibility to allow more frequent redemptions for retail investors
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 EUU, Alm.del - 2020-21 - Bilag 284: Notat samt høringssvar vedr. Europæiske langsigtede investeringsfonde (ELTIF’ere)
□
Yes
X
☐
No
□
Don’t know / no opinion / not
relevant
Please explain your answer to question 5.d and your suggested approach if you
responded yes:
e)
Procedures and arrangements to deal with retail investors complaints
□
Yes
□
No
☐
Don’t know / no opinion / not relevant
X
Please explain your answer to question 5.e and your suggested approach if you responded
yes:
f)
Provisions related to the marketing of ELTIFs
□
Yes
□
No
☐
X
Don’t know / no opinion / not relevant
Please explain your answer to question 5.f and your suggested approach if you responded
yes:
g)
Other provisions and requirements related to retail investors
☐
Yes
X
□
No
□
Don’t know / no opinion /
not relevant
Please explain your answer to question 5.f and your suggested approach if you responded
yes:
Denmark believes that the requirements related to retail investor protection should
be equivalent with the requirements in the MiFID regulation
Question 6. You are kindly invited to make additional comments on this consultation if
you consider that some areas have not been adequately covered above.
Please elaborate, more specifically, which amendments of the ELTIF framework could be
beneficial in providing additional clarity and practical guidance in facilitating the pursuit
of the ELTIF strategy?
 EUU, Alm.del - 2020-21 - Bilag 284: Notat samt høringssvar vedr. Europæiske langsigtede investeringsfonde (ELTIF’ere)
Please include examples and evidence on any issues, including those not explicitly
covered by the questions raised in this public consultation:
No opinion