Annual Report - AMAFIamafi.fr/storage/snippet/596thiCcmhm20ZWa5VoNUZyljh4... · 2018. 6. 14. ·...

Annua

l Rep

ort

Editorial ........................................................................................................................................................................ p.3

Full-time staff ............................................................................................................................................................ p.4

Highlights .................................................................................................................................................p.5

A new situation in Europe .............................................................................................................................. p.6

A continually evolving business framework ...................................................................................... p.13

Profile .................................................................................................................................................................p.21

AMAFI ............................................................................................................................................................................ p.22

Our media tools ...................................................................................................................................................... p.26

Standing committees ........................................................................................................................................ p.27

Our members........................................................................................................................................................... p.30

External bodies in which AMAFI is involved ...................................................................................... p.32

Sent to press on 15 May 2017

Key figures 2016

Consultation responses23

Analytical memos and position papers11

Briefing memos20

Members140

Standing committees9

Working groups25

Conferences and events16

Professional standards3

Professional best practices3

Annual Report 2016 AMAFI 3

A mong the many events impacting financial mar-kets in 2016, two will radically alter the environ-ment in which the firms represented by AMAFI

currently operate. The first is the UK referendum deci-sion to leave the European Union (EU), at a time when the bulk of Europe’s financial expertise is centred in London. The second is the announcement by the newly elected US president that he would pursue forceful pol-icies, notably on deregulation, which are likely to affect the financial industry.In both cases, Europe is in the forefront. True, the impli-cations of Brexit go far beyond the future relationship with the City. However, bearing in mind the key role that markets have played in responding to the financial crisis, the other 27 member states need to pay much closer attention to this issue. The EU can hardly accept that much of the capital needed to grow its companies and to fund its members’ debt depends on skills that will eventually lie beyond its purview and over which it will have little or no supervision. The EU will have to find ways of addressing the impending challenges and ensuring that it keeps control of its financing – and to do so without harming the financial industry by being overly protectionist. This is especially important since these challenges have a global reach, given the major efforts made at the instigation of the G20 and the Financial Stability Board to harmonise the oversight of financial activities. In this respect, Brexit and the outlook for US deregulation have opened up the EU to the dangers of greater market fragmentation, which entails a loss of efficiency and hence a higher cost of capital and hedg-ing for companies.These challenges face not only Europe but also France. Despite a lack of awareness at national level, our coun-try is second only to the UK in having a highly devel-oped financial industry. Consequently it should aim, as

far as possible, to fill the vacuum left by London. It should do so firstly in order to elicit and encourage the vital deliberations the EU must engage in to identify the markets it needs and wants within the Union. Its sec-ond aim should be to profit from plans to relocate busi-ness – and thus high value-added jobs and collective wealth – that are currently being pondered by City-based firms amid uncertainty over the final outcome of Brexit negotiations.But to meet these dual aims and turn challenges into opportunities, France needs to openly acknowledge its shortcomings and mitigate them as quickly as possible. Not the least of these deficiencies, as reflected in AMA-FI’s annual survey, is the way savings are taxed. Our association took advantage of the French presidential election campaign to address some wider concerns in an open letter containing 16 concrete proposals, which it sent to all the would-be candidates in October 2016. Throughout the coming months, while forging ahead with work on a range of regulatory issues facing its members, AMAFI will also continue to bring these pro-posals to the attention not only of the newly elected government but also its other talking partners, notably the European institutions.

Editorial

Stéphane GiordanoChairman

Pierre de Lauzun Chief Executive

4 AMAFI Annual Report 2016

Full-time staff

The Board at 1 June 2017Sophie AsselotNatixis

Anthony AttiaEuronext Paris

Xavier BoisseauHSBC Bank PLC Paris Branch

Francis CanardKepler Cheuvreux SA

Benoît CatherineExane

Grégoire CharbitOddo et Cie

Arnaud de BourrousseOcto Finances SA

Pierre GayCrédit Agricole CIB

Stéphane Giordano Société Générale GBIS

Régis KhaberAurel BGC

Jean-Bernard LaumetExpert

Eric Le BoulchCIC

Christelle LefebvreBNP Paribas

Jean-Paul Péchery Rothschild & Cie Banque

Vincent RemayTradition Securities and Futures

AdvisorsPhilippe de Portzamparc Portzamparc Société de Bourse

Philippe Tibi Expert

Market Activities

Emmanuel de FournouxDirector, Market [email protected]

International Affairs – Commodities Markets

Véronique DonnadieuDirector, International Affairs – Commodities [email protected]

Market Activities

Faustine FleuretAdviser, Market [email protected]

Compliance

Blandine JuléAdviser, [email protected]

Legal Affairs

Sylvie DariosecqDirector, Legal Affairs Member of the New York [email protected]

Compliance & Legal Affairs

Chloé GonzalezAdviser, Compliance & Legal [email protected]

Tax Affairs

Éric VacherTax [email protected]

Assistant

Sylvia GiannoneCommunications, Compliance & Legal, [email protected]

Assistant

Sicile RouilléMarket Activities, International & Tax [email protected]

Assistant

Corinne ChassagneSocial Affairs & [email protected]

Chief Executive

Pierre de [email protected]

Deputy Chief Executive

Bertrand de Saint Mars [email protected]

Social Affairs, Administration

Alexandra Lemay-Coulon Director, Social Affairs & [email protected]

Communications & Member Relations

Philippe BouyouxDirector, Communications & Member [email protected]

Compliance

Pauline LaurentDirector, [email protected]

Stéphane GiordanoChairmanJean-Bernard LaumetVice-Chairman

Vincent RemayVice-ChairmanArnaud de BourrousseTreasurer

Pierre de LauzunChief Executive

The Executive Committee at 1 June 2017

HIGHLI

GHTS


A new strategy needed for EuropeIt took the UK almost a year to serve official notice that it was leaving the EU. The process was formally triggered on 29 March 2017, signalling the start of talks that look set to be complex and difficult, whilst spelling upheaval for Europe’s City-dominated financial system.

Tense talksThe terms of the talks between the EU and the UK are becoming tougher with the passing months. After saying that “a non-member of the Union, which does not have the same obligations as a member, cannot have the same rights and enjoy the same benefits as a member”, the European Council proposed a two-phased approach to the negotiations on 29 April, reiterating the “principle that nothing is agreed until everything is agreed”: thus, the first phase will aim to “provide as much clarity and legal certainty as possible to citizens, businesses, stakeholders and international partners on the immediate effects of the United Kingdom’s withdrawal from the Union” and “settle the disentanglement of the United Kingdom from the Union and from all the rights and obligations the United Kingdom derives from commitments undertaken as a Member State”. The UK will have to foot a bill estimated at between €60 billion and €100 billion in this regard. In the UK, meanwhile, whereas the roadmap presented in January 2017 by Prime Minister Theresa May reflected an intention to pursue a ‘hard’ Brexit, it seems less clear now that such an outcome is achievable within the framework of the “comprehensive, bold and ambitious” new partnership that the UK hopes to build through a free trade agreement and a customs agreement.

An opening for Paris?While uncertainty remains about the terms under which they will be able to continue selling their products and services into the EU, London-based financial firms face reorganisational choices if they want to continue providing the best possible service to their European customers. As a result, Brexit is creating competition between continental financial centres, particularly between Paris and Frankfurt, as they vie to attract relocating firms. France’s capital has unquestionable advantages, including a skilled workforce, central geographical location, position in the euro area, and great quality of life, but it has genuine drawbacks as well, including one major stumbling block in the shape of its unfavourable tax and social ecosystem, which suffers additionally from negative perceptions. Frankfurt, moreover, is a serious rival, not least because it is home to the European Central Bank (ECB), a key rallying point for financial market participants.

A new situation in Europe

On 23 June 2016, Britain voted to leave the European Union. This was a seismic event for all of Europe, of course, but especially for the financial sector, given the importance of the City of London. Brexit will reshape Europe’s financial landscape. Yet it also creates an opportunity for the Paris financial centre, which would be a natural candidate to take over as the Union’s leading marketplace provided the handicaps holding it back are removed. For this reason, in late October 2016, AMAFI sent an open letter to all the candidates in France’s presidential election, presenting 16 proposals that work through the consequences of the new European situation to chart out a strategy for France and Europe.

AMAFI tax conferences: Brexit sharpens the focus of discussionIn September 2016 and then again in January 2017, AMAFI held conferences on Brexit-related tax developments.

Co-organised with EY Société d’Avocats, the first conference looked at the immediate tax effects and regulatory changes resulting from Brexit, notably in terms of the organisation and structure of financial groups.

Meanwhile, the seventh annual conference on financial sector tax issues, which was held in partnership with Taj-Société d’Avocats, considered whether Brexit might prompt France to take steps to improve its tax attractiveness. In addition to covering case law developments, the event was a chance to spotlight AMAFI’s contribution to the public debate with its annual barometer of savings taxation and business finance, and proposals to strengthen the Paris financial centre (AMAFI/16-47).


For a number of months now, AMAFI has been playing an active part in initiatives by Paris Europlace to position the French financial centre favourably as London firms weigh their options. In July 2016, Prime Minister Manuel Valls, Valérie Pécresse, President of the Ile-de-France region, and Anne Hidalgo, Mayor of Paris, announced measures to make Paris more attractive. Although they do not go far enough, which is regrettable given what is at stake in terms of jobs and collective wealth, these measures include an extension of the regime for “inpatriates”. A communication plan targeting affected foreign firms is now being rolled out. However, given that Paris has not emerged as a preferred location in the first round of decisions to be announced, the ability to attract these firms will remain largely dependent on steps taken by the government formed after the elections that are underway at the time of writing.

A role for FranceOne of the challenges posed by Brexit is that it forces the EU-27 to consider the shape of Europe’s future financial system. Until now, this question has never been an urgent one because of the presence of the City, which has steadily increased its clout over the years to become the central hub for the players that finance the EU economy and allocate EU savings. With its expertise, London has naturally played a pivotal role in setting European rules for market functioning and market participants. This will no longer be the case going forward. By the end of the two-year talks that recently got underway, the EU-27 could find itself in the strange and unique situation of being a leading economic area whose financial brain is largely located outside the zone.There is role here for France. Though it is often overlooked, France is, after the the UK, the EU country where financial activities are most developed. And in the AMF, it boasts a market regulator with rock-solid credibility. Furthermore, looking beyond the worthy but ultimately fairly modest Capital Markets Union (CMU) initiative, France needs to be right at the heart of discussions that Europe cannot put off any longer. What markets and participants do Europe’s economy and savings need? What kind of finance does Europe want in its territory? These key questions have become even more critical given the conditions under which the Brexit negotiations are getting underway. The talks, which are likely to be tough, will be comprehensive in nature, encompassing many commercial and industrial issues. Accordingly, there is a danger that financial aspects might not get the priority that they deserve.

Open letter to the candidates in France’s presidential electionIn October 2016 AMAFI wrote a letter to all of the candidates in France’s presidential elections in May 2017 to make them more aware about Brexit and its attendant risks, opportunities and challenges. To this end, it put forward 16 practical proposals (AMAFI/16-47) organised around five action areas:> Recognise the importance of capital market activities when negotiations with the UK get

underway.> Ensure that savings taxation is consistent with business funding needs.> Channel new savings flows into long-term investment.> Adjust the tax system to accommodate equity financing requirements.> Seize the opportunities arising from Brexit by adopting a clear-sighted plan for capital

markets in France.When it comes to delivering the growth that France needs, one of the biggest issues is long-term funding for businesses. French savings need to be channelled towards this goal, which will entail revising the associated tax arrangements. Bold steps are also needed to develop French-style pension funds to supplement the pay-as-you-go system. One way to achieve this would be by reactivating the pension reserve fund set up in 2001.

LSE-DB merger off the tableIn March 2016 Frankfurt-based Deutsche Börse and the London Stock Exchange announced plans to merge, creating a stockmarket giant capable of competing with US and Asian rivals. After shareholders gave their consent, the merger was submitted for a review by the European Commission’s DG Competition last August in view of the share that the new entity would have in several business segments.

This proposed merger raised several issues for AMAFI (AMAFI/16-20), notably concerning the acquisition of a dominant position in specific market segments, such as clearing or indices, as well as the risks for users in terms of innovation and costs. AMAFI also pointed out that the draw of such a powerful grouping for major issuers could be detrimental to other market platforms that finance smaller businesses. It raised these points in its feedback to the questionnaire sent to it by DG Competition. AMAFI was also part of the group set up for this purpose by Paris Europlace.

With Brexit further complicating the merger process, the proposed tie-up ultimately foundered in early April 2017 on the LSE’s refusal to agree to demands to sell its majority stake in MTS, an Italian electronic trading platform specialised, among other things, in European government bonds.


Analyse in detail the terms of the talks that are set to open with the UK on market finance, with the aim of ensuring the autonomy and security of the EU-27 system of finance, and use this as a basis for raising awareness at European level.

Adjust the structure of savings taxation so that long-term business financing – chiefly through equity but also via fixed-income investment – is recognised as a national priority.

As part of this structural reform of taxation, allow dividends and capital gains from securities disposals to be subject to a 27% flat-rate withholding tax in lieu of personal income tax and welfare contributions, at the discretion of the beneficiary.

Provide PEAs (equity savings accounts) and PEA-PMEs (which specifically target the shares of small and mid-sized companies) with incentives to give them mass appeal and rekindle interest in equity investment.

Reinstate the initial purpose of the pension reserve fund (FRR) to create a powerful investor with a very long-term horizon that can benefit the entire French economy.

Create popular equity pension savings accounts (PERPAs) to encourage long-term savings more effectively and more credibly than the existing mechanisms. Enable PERPAs to draw on the FRR’s expertise in long-term investing.

Create investment savings accounts (PEIs) primarily invested in equities and offering advantages that are at least the same as those of unit-linked life insurance products, making it possible to address the problems associated with Solvency 2.

Tap into the innovative abilities of French entrepreneurs and strengthen this area through aggressive development of venture capital and business angels, while making Paris the leading financial centre in the field.

Harness the wealth tax, assuming it is maintained, to promote business investment, notably by removing the ceiling on the deduction for investments in growing SMEs.

Ensure that the tax treatment of equity financing for companies is at least equivalent to the treatment of debt financing and more advantageous as a rule.

Lower the company tax rate to the EU average.

Promote Paris as a venue where pan-European capital market activities can be efficiently centralised.

Withdraw France from Europe’s plan to introduce a financial transaction tax, which would have a damaging impact both on the financing of economic activity and the future of capital markets business in France.

Eliminate the payroll tax, potentially in stages. Failing that, exempt new hires (including inpatriates) from the tax for eight years.

Create a specific regime, reducing the protection provided by labour law for employees whose pay exceeds a set amount and potentially even waiving the provisions of the labour code if remuneration is beyond a certain level.

Include orderly market financing of the economy in the statutory tasks assigned to the AMF.

Presidential Election: AMAFI’s 16 proposals

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Taxation is still a drag on competitivenessFor the past few years, AMAFI has been regularly updating a tax barometer to assess France’s attractiveness in terms of business finance. The 2016 update highlights the current situation and compares France with its main economic and financial partners (AMAFI/16-46). The update points to a relative improvement from a peak that saw France become one of the most heavily taxed countries in the world owing to a combination of business and savings taxation. Even so, France is still at a high level compared with the European average. Our tax system remains overly complex and does not do enough to help businesses to set up and grow. Whereas national savings and the way these savings are channelled are crucial to the development of companies – especially SMEs, at a time when the weakness of our system of mid-sized firms is a recognised issue – France continues to tax residents that invest in their own economy far more heavily than its neighbours do. Even in northern Europe, where taxes are notoriously high to fund extensive welfare systems, the overall rate on savings (income and capital gains) tops out at 27% in Norway and 30% in Sweden. In France it is close to 40% on dividends and almost 60% on capital gains for shorter-term holdings and on interest in excess of €2,000 per year. However, France’s situation has improved slightly relative to its partners, especially the UK. This is essentially down to two factors: France got rid of its exceptional surtax on compa-nies, while Britain put up taxes on distributed income, affecting the highest earners.At a time when European nations are trying to make their financial centres more attractive, and when taxes are coming down in most countries (the UK has approved a multi-year tax-cutting plan with Brexit looming and Germany has announced a new €15 billion tax cut), it is urgent to change the way that France taxes savings.

Gross profit needed for a company to pay net income of 100 to investors subjectto an intermediate income tax rate

DividendsEquity financing

Interest Debt financing

Corporate income tax

Dividend tax

Income tax + social security charges

Investor net income

0,0

50,0

100,0

150,0

200,0

250,0231

195183

178

1364.5

46.8

100

79.2

100

35.8

58.8

100

48.2

34.8

100

78.5

100

35.8

France Germany UK France Germany

167

100

66.7

UK

Source: AMAFI /15-37

1. L'apporteur de financement d'entreprise est imposé à un taux marginal d'IR intermédiaire, soit : en France 30% et, au Royaume-Uni, 40 % sur les intérêts et 32,5 % sur les dividendes.2. Cette simulation est effectuée en intégrant le biais fiscal à l'endettement (intérêts déductibles, dividendes non déductibles, pour la determination du résultat imposable), toutefois des dispositifs nationaux peuvent limiter la déduction de charges financières mais sont difficilement modélisables et de portée limitée. Ils ne sont pas pris en compte dans la présente simulation.


Savings taxation in France

* Including deductible CSG levy but excluding the special CEHR levy on high incomes.Source : AMAFI/17-33. Taxation at 01/01/2017.

Savings product Social security charges Tax charges Total *

0%

Livret A / Livret Bleu / LDD / Livret Jeune passbooks

0% 0% 0%

Popular savings passbook (LEP) 0% 0% 0%

Lessthan20%

Home savings plan (PEL) less than 12 years

15.5%0% (if PEL<12 years)

Income tax (if PEL>12 years)15.5%

Home savings account (CEL) 15.5% 0% 15.5%

Popular savings plan (PEP) 15.5% 0% 15.5%

Equity savings plan (PEA) over 5 years

PEA-PME over 5 years15.5% 0% 15.5%

Life insurance > 8 years

DSK/NSK policies15.5% 0% 15.5%

Compte PME Innovation (vehicle for business-angel financing of innovative firms),

2016 supplementary budget act15.5% Income tax 15.5%

Equity capital gains

Special regime (85% reduction if securities held for more than 8 years)

15.5% Income tax 19.96%

20% to

30%

Life insurance > 8 years

Non-DSK/NSK policies15.5%

Income tax or (option) 7.5% flat-rate withholding tax

23% (flat-rate withholding tax)


Ordinary regime (65% reduction if securities held for more than 8 years)

Special regime (65% reduction if securities held for 4-8 years)

15.5% Income tax28.96%

(Income tax)

30% to

40%

Life insurance 4-8 years 15.5%Income tax or 15% flat-rate

withholding tax30.5%

(Income tax)

PEA over 2 years and less than 5 years

PEA-PME over 2 years and less than 5 years15.5% 19% 34.5%


Ordinary regime (50% reduction if securities held for 2-8 years)

Special regime (50% reduction if securities held for 1-4 years)


(Income tax)

PEA less than 2 years

PEA-PME less than 2 years15.5% 22.5% 38%

PEL more than 12 years 15.5%Income tax or 24% flat-rate

withholding tax39.5% (flat-rate withholding tax)

40% to 50%

Equity dividends 15.5% Income tax40.21%

(Income tax)

Over50%

Life insurance less than 4 years 15.5%Income tax or (option) 35%

flat-rate withholding tax50.5% (flat-rate withholding tax)


Ordinary regime if securities held for less than 2 years

Special regime if securities held for less than 1 year

Ordinary passbooks

Capital gains and interest on bonds and debt securities


(Income tax)


Household financial investments in Q4 2016

€ billion %

Liquid, non-risk assets 1,092.30 22.92

Cash 72.60 1.52

Sight deposits 414.40 8.70

Passbooks, home savings plans and accounts 595.90 12.51

Money market fund shares/units 9.40 0.20

Illiquid, non-risk assets 1,970.70 41.36

Time deposits 70.80 1.49

Contractual savings 279.50 5.87

Non-unit linked life insurance 1,620.40 34.01

Liquid, risk assets 582.00 12.21

Debt securities 65.10 1.37

Listed shares 237.60 4.99

Non-money market fund shares/units (inc. employee profit-sharing funds)

279.30 5.86

Illiquid risk assets 1,119.70 23.50

Unlisted shares and other investments 819.10 17.19

Unit-linked life insurance 300.60 6.31

Total financial investment 4,764.70 100.00

Total - Listed shares and unlisted shares 1,056.70 22.18%

Source: Banque de France – Épargne des ménages – 17/05/2017.


0

10

20

30

40

50

60

70

France UnitedKingdom

Germany Spain Italy DenmarkSweden Belgium Luxembourg Netherlands SwitzerlandUSA

Exemption of capital gainson sale of securities

Differentiated taxation of interest

Clear and simple

Savings taxation comparisonsMarginal tax rates (2016)

Interest Dividends Capital gains (base rate) Other possible tax rates on capital gains

Savings taxation in France: share of taxesFrance tops the list when it comes to taxing interest and capital gains. The taxation rate stands at 58% for a taxpayer in the 45% bracket and 54% for a taxpayer taxed at the marginal rate of 41%. Only the dividends regime is a little less onerous, owing to the 40% allowance. The overall tax rate stands at 40% for a taxpayer taxed at the marginal rate of 45% (38% for a taxpayer in the 41% bracket). This is slightly less than in Denmark but more than in most other European countries. Based on these numbers, AMAFI estimates that a French company has to generate between 12% and 20% more profit than UK or German firms in order to pay its shareholders the same amount. Specifically, to pay net income of 100 to shareholders, a French company needs to make gross profit of 231, compared with 195 for German firms and 183 for UK companies. Another consequence of this situation is that French people allocate just 22% on average of their financial investments to equities.

In addition to high nominal tax rates, France taxes capital in ways that differ from other countries:

> Taxation of investment income is sharply progressive, with rates ranging from zero to 60%, whereas other countries apply a single withholding rate of some 25%-30%;

> Proportional social insurance contributions are charged on top of income tax;

> Wealth tax – a third progressive tax – is levied in some cases, calculated on the basis of capital ownership (whereas other countries have long since scrapped this measure).

France’s system of taxation is uniquely complex. Three different regimes apply to interest, dividends and capital gains on securities. France is the only country to have a system of allowances based on the length of investment. If an investment is held for more than eight years, the tax regime becomes more advantageous (the rate falls to 28% rather than 58%) but this is hard to see in international comparisons.

Source : AMAFI/16-46.


MiFID 2: a multi-faceted projectThe magnitude and number of the changes required by MiFID 2 must not be underesti-mated. Market participants and regulators alike face the challenge of managing a variety of impacts to market structure and customer relations, which represent a considerable step-up from MiFID 1. In fact, discussions on implementing the new framework have revealed that many of these impacts were not fully measured at the outset. What is more, in some instances, the actual benefits of the proposed restrictions remain to be demon-strated. Meanwhile, Brexit is raising new questions given London’s place in market activities.Responding to these complicated circumstances, the European Commission proposed in February 2016 to push back the framework’s application date by one year. Officially, this was to deal with difficulties encountered by the European Securities and Markets Authority (ESMA) in establishing the requisite databases and defining certain Level 3 measures. But the postponement, which had been widely called for by members of the financial com-munity, including AMAFI, was also vital because although the Level 2 measures were broadly known, they were not officially published until 31 March 2017, and even then only partially.Against this backdrop, AMAFI pursued its discussions over the course of 2016 with the AMF and also with ESMA on Level 3 guidelines. Conducted variously by the Market Struc-ture, Compliance, Commodities and Legal Committees, these exchanges were mostly prepared and initiated within different working groups, including:> MiFID 2 Project Managers (market structure and best execution)> Product Governance> Expenses and Charges> AMAFI – AFTI Regulatory Reporting> MiFID 2 Jurisdiction (territorial scope of MiFID 2)> Commodities Q&A (position reporting).

Market structure at the heart of many discussionsThere are numerous issues in this area, including obligations for systematic internalisers in relation to OTC derivatives, registration of OTC derivatives, best execution reports and the conditions under which investment firms that still engage in voice trading can continue doing business.In the lead-up to the Q&As that ESMA began publishing in autumn 2016, AMAFI held dis-cussions throughout 2016 and still continues to talk with the AMF and ESMA on all these issues to find pragmatic solutions that are in synch with the wishes of the co-legislators.

A continually evolving business frameworkIn recent years, this annual report has spoken about the many pieces of legislation introduced in response to the financial crisis and the major changes that they have brought to the framework within which market participants operate. Aside from those linked to the Capital Markets Union, including the revision of the Prospectus Directive, most of these laws and regulations have been adopted now for several months or even years. Yet not all of them are being applied. Those that are, moreover, still have outstanding aspects requiring clarification. Accordingly, AMAFI was busy again in 2016 working on a wide range of regulatory projects. Of these, the MiFID 2 framework is unquestionably the most complicated to implement, but the new Market Abuse and PRIIPs frameworks also raise questions that must be resolved.


For participants, with just a few months left before the framework comes into effect and many questions still outstanding and not addressed by Level 1 and 2 measures, it is urgent to prioritise.Furthermore, the risk of a market seize-up has been identified. The issue lies with the fact that market operators need to modify their order management and data dissemination systems to comply with the new regulatory requirements. They must share their new technical specifications sufficiently early for market members to adapt their own systems and carry out testing. This issue is especially concerning because there are many markets operating in Europe, and members’ resources are finite. AMAFI has set up a group spe-cifically to assess the risk and, if necessary, suggest measures to respond to the situation. It has established three lines of action: alert markets that have not yet shared their MiFID 2 functionality deployment plans; alert the Federation of European Stock Exchanges to lobby for maximum harmonisation in terms of the way in which members are obliged to provide the new information required under the MiFID Regulation; and alert regulators to potential non-compliance risks when MiFID 2 starts up.Last, the trade reporting regime is a major issue, given the scale of IT developments entailed. On this topic, in December 2016 AMAFI and AFTI wrote to ESMA’s Chair (AMAFI/16-59) to highlight a number of provisions in the guidance published by ESMA in October 2016 that are incompatible with the way the French market works.

Regulating payment for investment researchInvestment research is a matter of huge importance for companies that raise funds on capital markets. Not only is research essential for generating investor interest, it also plays a crucial role in stimulating dialogue and thus in lowering the cost of capital for issuers. That is why the French public authorities, the AMF and members of the Paris financial centre have been trying for years to find ways of increasing the amount of research on small and mid-sized businesses, which is often lacking. The European Commission itself has noted that much less research is done on these firms than for large caps and that the issue ought to be addressed. Yet the Commission has decided to heed ESMA proposals on a framework of rules for the remuneration of investment research that would seriously undermine the economic viability of an activity already shaken by the crisis.The publication in summer 2016 of a delegated directive containing a number of provisions on inducements linked to research raises a number of questions (AMAFI/16-28) involving issues such as the scope of activities covered, the relationship to the commission-sharing arrangements in the equity segment, management of research budgets by asset man-agement companies, and the treatment of credit research. Looking ahead to the introduction of this framework, the AMF launched a consultation in September 2016 to provide clarification on operational procedures. While hailing the con-sultation paper’s pragmatic and open approach, AMAFI nevertheless said (AMAFI/16-49) that, in an environment impacted by Brexit, the AMF should take advantage of the latitude offered by the delegated directive to implement a framework tailored to the specific fea-tures of the French ecosystem and to enable a sensible transition to the new standards. The aim should be to avoid unnecessarily disrupting affected participants, whether they be management companies or research providers, particularly given what is at stake in terms of the market’s ability to play its role in providing financing for mid caps. Whatever the case, it is regrettable that the new framework adds considerably to the red tape for management companies of all sizes. The main challenge facing research providers will be to reposition their offerings to reflect the constraints on their customers and seize the opportunities opened up by the new regime.

MiFID 2 Conferences In 2016, AMAFI organised two MiFID 2 conferences. The first, on 16 February, dealt with future developments for market organisation under MiFID 2. It was a chance to take stock of progress in Level 2 measures and transposition efforts, review the timetable and shed light on operating challenges in implementing the framework. The second conference, held on 21 June, was focused on investor protection. It afforded an opportunity to talk about compliance-related developments and issues raised by the marketing of financial instruments, particularly in terms of product governance. In connection with the conference, AMAFI published a presentation providing an overview of the main provisions contained in the regulation and delegated directive in the areas addressed.

AMAFI plans to hold a third MiFID 2 conference on 4 July 2017.


Strengthening product governanceIn view of their implications, product governance aspects have been a central focus of discussions on investor protection. They were recently addressed by the publication of the first version of the AMAFI Guide to implementing product governance requirements (AMAFI/17-22). Although initially drafted by a working group mostly made up of product producers, the guide also took account of observations from distributors. The guide, which additionally draws on conversations with the AMF and other industry associations, sketches out collectively thought-out ways forward in terms of standardising target market criteria and updating distribution agreements.AMAFI also responded to the consultation launched in October 2016 by ESMA on pro-posed product governance guidelines (AMAFI/16-61). While the proposals are in line with work done by the AMF in partnership with the financial community, AMAFI nevertheless raised a number of concerns, relating to: > The need for a bolder approach in terms of applying the proportionality principle to target

market identification;> Inadequate recognition of the importance of diversification for customer portfolios;> Confirmation that target market verifications may be performed only based on the infor-

mation available on the customer, which in turn is linked to the nature of the service provided by the distributor.

Disclosing expenses and chargesRequirements to disclose expenses and charges are one of the many problem areas raised by MiFID 2. AMAFI and a number of other industry associations wrote a joint letter to ESMA stressing the importance of proper consultation on the Level 3 measures currently under discussions. AMAFI also met with ESMA to voice the concerns of its membership, particularly regarding cost calculation methodologies and transparency procedures (AMAFI/17-18).

Regulating commodity marketsIn December 2016, ESMA published a first version of its Q&A on commodity markets. However, the document leaves many questions unanswered, particularly concerning the practicalities of position reporting, for which no Level 2 measures are planned. AMAFI therefore decided to set up a working group to provide input to ESMA’s work in this area by suggesting Q&As. The proposals, discussed with the AMF, were submitted to ESMA, which reviewed them in its Commodities Task Force. However, it appears to be hard for regulators to reach consensus on these issues.

Focus on the target marketThe obligation to identify a target market, as part of financial instrument governance, is at the heart of the product governance system and a critical issue for affected institutions. For this reason, AMAFI urged the AMF, ESMA and the European Commission to remember the need to prioritise an approach that is proportionate to product complexity, to avoid unduly curtailing the options for distributing financial instruments to investors, particularly since these products play a direct role in financing businesses ESMA responded in early 2016 to AMAFI and the other European associations that acted with it, by confirming that the provisions covering product governance are supposed to apply appropriately and proportionately to affected financial instruments. In its guide to product governance, AMAFI proposes an operational and standardised breakdown of the criteria used to identify the target market.

Target Market

Client type

> Retail

> Professional

> Eligible couterparty

Knowledge and experience

> Basic knowledge or experience

> Knowledge or experience of financial markets or the asset class

> Knowledge or experience of financial markets and the asset class

Ability to bear losses

> Capital guaranteed

> Capital partially protected

> No capital guarantee

> Risk of capital loss greater than invested amount

Risk tolerance

> Low

> Medium

> High

Client objectives and needs

Investment profile

> Preservation> Growth> Income> Hedging

Investment horizon

> Short term> Medium term> Long term


Relieving asset management companies of investment firm statusWith the 3 July 2017 deadline for Member States to transpose the MiFID 2 framework drawing nearer, the Treasury consulted the industry on the final provisions to be adopted by executive order, which will round out those already introduced by Executive Order No 2016-827 of 23 June 2016 (AMAFI/16-42). The consultation also covered proposed amend-ments to relieve asset management companies of investment firm status, in accordance with the authorisation given to the government by the Sapin 2 Act of 9 December 2016. While supporting the notion of relieving asset management companies of investment firm status, which would be consistent with the architecture set up at European level, AMAFI highlighted the drawbacks associated with the option that was taken to continue consid-ering asset management companies as “prestataires de services d investissement” even if they do not provide investment services (AMAFI/17-15). AMAFI argued that this will not help to make French law clearer and introduces complexities that could have been avoided had a different approach been taken. It also made several technical observations that were noted by the Treasury.

The Market Abuse framework: one year onA new instrument designed to enhance the integrity of financial markets and investor protection, the renewed Market Abuse framework, comprising a Regulation (MAR) and a Directive (MAD 2), came into force on 3 July 2016. After the last remaining Level 2 measures were released between March and June 2016, AMAFI published a briefing paper in mid-July on the main features of the new framework (AMAFI/16-32).AMAFI also responded to the AMF’s May consultation on amendments to its General Regulation and policy to accommodate MAR. The association underlined the importance of clarity and provided feedback on the AMF’s proposals, aimed at removing, changing or keeping various provisions contained in the Regulation (AMAFI/16-26).In addition, in February, AMAFI updated (AMAFI/17-13) its MAR Q&A, after publishing a first version in June 2016 (AMAFI/16-29). The association used the update as an oppor-tunity to expand the Q&A to include new questions on market soundings, and particularly on the definition and scope of soundings applied to real-life situations commonly encoun-tered by members, such as credit updates, deal roadshows and block trades. AMAFI is now working to expand the Q&A to include its thinking on investment recommendations.

Inside information on commodity marketsESMA published guidance on the definition of inside information within the market abuse framework, applied to commodities. Specifically, the guidance clarifies the notion of “infor-mation which is reasonably expected to be disclosed or is required to be disclosed in accordance with [the legislation in effect]”. Most of AMAFI’s feedback (AMAFI/16-23) to the consultation on the subject is included in the guidance. The chief difficulty for partic-ipants on these markets lies with the vast scope of information to consider, especially on physical markets.

Liquidity contracts under the spotlight The framework for liquidity contracts was established in 2001 by AMAFI, working in close partnership with COB, the AMF’s predecessor. Since 2005, this framework has been covered by an AMF Accepted Market Practice (AMP), under which arrangements satisfying the specified criteria are covered by a safe harbour with respect to the rules preventing and punishing price manipulation. Amended in 2008 and 2011, the AMP has been a rec-ognised success, with almost 450 listed companies signing liquidity contracts in a bid to promote liquid trading in their securities by supporting liquid transactions and regular quotations while avoiding price swings not warranted by market trends. For issuers, what is at stake is the cost of capital because secondary market liquidity depends directly on the level of the liquidity premium required by investors when issuers go to the primary market to raise funds. This explains why the approach has been replicated since 2007 in Spain, Italy, the Netherlands and Portugal, even if rigidities introduced by the authorities in those countries mean that it remains considerably less widespread outside France.

Definition of investment recommendationsMAR’s definition of investment recommendations raises challenges because of the potential impact on procedures for producing and distributing such recommendations. This is why AMAFI endeavoured to identify the factors underpinning the definition with a view to providing operational guidance about the communications likely to be captured by the definition (AMAFI/16-43).

Clarifying the scope of territorial applicationWork launched in 2016 on clarifying the territorial scope of application of certain provisions of the MiFID 2 Directive and Regulation, notably as regards the branches of investment firms located outside the European Union, was completed in early 2017 (AMAFI/17-05). Overall, aside from a few extensions outside the Union, the MiFID 2 framework is deemed to apply essentially to business conducted within the Union by European entities that are investment firms.


Updating the AMAFI-FBF Guide to reporting suspicions of market abuseIn early 2017 AMAFI sent a revised version of its Guide to the AMF for discussion. The aim is not only to build in changes stemming from MAR but also to capitalise on feedback about the existing system. Accordingly, AMAFI is looking to extend the classification of potential market abuse and indicators of abuse, while accommodating the peculiarities of certain markets and products, such as commodities and mid caps.

The entry into force in July 2016 of MAR, which introduced a number of amendments to the conditions applicable to AMPs, led to a review of the existing mechanism. The AMF and AMAFI held discussions on this topic over the course of 2016. Some of the avenues proposed by the AMF are not required by the European framework and could place sig-nificant restrictions on the way that liquidity contracts currently operate in France (AMAFI/17-20). In the end, these restrictions could affect the contracts’ capacity to meet the goals assigned to them, and hence the orderly operation of the Paris market, notably when it comes to serving small and mid-sized firms. For this reason, AMAFI, AFEP, Medef, Middlenext, AFG and SFAF wrote to the AMF Chairman in March 2017 to voice their con-cerns about some of the proposed changes to the AMP for liquidity contracts. Discussions are underway to identify solutions that, while meeting the requirements stem-ming from the European framework and the AMF’s legitimate supervisory needs, will enable liquidity contracts to continue to perform their role in an effective manner.

PRIIPs: a welcome postponement in view of the challengesThe Packaged Retail and Insurance-based Investment Products (PRIIPs) Regulation, pub-lished on 9 December 2014, sets down the standardised precontractual information to be provided to consumers before they buy an investment product. This information is provided in the form of a key information document (KID), whose content and format are strictly defined. The purpose is to enable retail investors to easily compare the different types of investment products offered to them and understand their main features before investing. The Level 2 measures (regulatory technical standards, RTS) drawn up by the three Euro-pean supervisory authorities – ESMA (financial markets), EBA (banks) and EIOPA (insur-ance) – and adopted by the European Commission were rejected in autumn 2016 by the European Parliament, which also asked for the mechanism’s entry into force, originally set for 1 January 2017, to be pushed back by a year. The proposal to postpone was ultimately accepted. AMAFI had repeatedly called for such a decision not just because of the cum-bersome and complex process required to implement PRIIPs, but also because of the delays in drafting the legislation. In this setting, AMAFI conducted various initiatives to help members get to grips with PRIIPs. In particular, AMAFI held talks with the AMF about a Q&A prepared by AMAFI, whose first version was published in February in French before being translated into English (AMAFI/17-12). The aim is to identify points requiring particular attention or posing inter-pretation difficulties, keeping in mind that the European Commission is scheduled to publish a Level 1 Q&A and ESMA is expected to publish Level 3 measures at the beginning of H2 2017. AMAFI also notified the regulator about issues raised by proposed amend-ments to the RTS, notably concerning the methodology used to calculate stress scenarios and the criteria used for comprehension alerts (AMAFI/16-55).

In France, the 2017 Finance Act introduced measures that make the financial transactions tax (FTT) framework even more severe. First, the new legislation proposes to tax intraday transactions beginning on 1 January 2018, but with no certainty as to France’s legal ability to tax transactions conducted abroad by non-residents, which do not give rise to a transfer of ownership as defined by domestic law: yet this is a key element in the cross-border applicability of a framework designed to prevent the relocation effects previously noted with the tax on stockmarket transactions. Second, the tax rate was raised from 0.20% to 0.30%, with no recognition of the fact that this represents a new levy worth half a billion euros on equity savings, which already suffer from harsh tax treatment despite their importance to business financing (AMAFI/17-01).

Within Europe, meanwhile, ten Member States (Austria, Belgium, France, Germany, Greece, Italy, Portugal, Slovakia, Slovenia and Spain) are pursuing their work

on a European FTT under the enhanced cooperation procedure. While the broad principles were reaffirmed in October 2016, the project’s inherent difficulties, which are being exacerbated by Brexit, are becoming increasingly apparent. In any event, effective implementation of a European FTT cannot happen before the start of 2018 at the earliest.

In the final quarter of 2016, AMAFI was interviewed by the Cour des Comptes, France’s Court of Auditors, as part of an assessment of the French and European frameworks. This hearing was an opportunity to point out the FTT’s extreme complexity, as highlighted by the Implementation Guide published and regularly updated by AMAFI (AMAFI/17-08), as well as the issues associated with taxing intraday transactions (AMAFI/15-56). On the question of the European FTT, AMAFI stressed the destructive impact on business that the tax would have if applied to derivatives (AMAFI/15-53) and market making.

FTT: tougher measures at home amid growing difficulties at European level


What next for the Capital Markets Union (CMU)?In July 2014, European Commission President Jean-Claude Juncker unveiled a set of guidelines in a document entitled “A New Start for Europe: My Agenda for Jobs, Growth, Fairness and Democratic Change”. These proposals called for the creation of CMU. The CMU initiative comes at a crucial time. To grow, Europe must make it easier for compa-nies, particularly smaller and mid-sized businesses, to raise financing on capital markets. Following the consultation launched in February 2015 based on the Green Paper “Build-ing a Capital Markets Union” (AMAFI/15-28), in early 2016, the Commission put out a call for evidence to identify difficulties created by existing legislation, by gathering infor-mation on overlapping, inconsistent or unwanted rules that might compromise the econ-omy’s capacity to finance itself and grow. AMAFI answered the call by emphasising the priorities that should guide the assessment of the European legislative framework (AMAFI/16-08). In AMAFI’s view, the work done so far falls short of the stated goals, as reflected notably in the European Commission’s proposals on securitisation and the revision of the Prospectus Directive.In January 2017, the European Commission began a CMU mid-term review. The aim was to take stock of legislative initiatives undertaken since 2015 and gather feedback from stakeholders on positive aspects of and possible improvements to the action plan. AMAFI once again provided input (AMAFI/17-24), stressing the need for in-depth discus-sions on Brexit’s consequences for the EU-27 financial system and arguing that the fact that Europe’s main financial centre will soon be outside the Union should provide the impetus for the EU-27 to ensure its financial autonomy and security and adopt a clear policy for the treatment of third countries.

Upgrading the Prospectus DirectiveOn 30 November 2015, the European Commission published a proposal for a Prospectus Regulation to replace the 2003 directive. This is a key component of the CMU project. AMAFI, working with the Treasury, kept a close watch on the draft changes covered by the proposal in the subsequent trialogue discussions, proposing some 20 amendments of its own. While the regulation is expected to be definitively adopted following the trialogue discussions and published shortly, shortly after the report has been finalised, attention is turning to the Level 2 measures, which are currently being drafted but about which no details are yet available. Expectations are especially high concerning the streamlined requirements for the new EU Growth Prospectus, whose aim is to follow through on one of the key goals of the new regulations, namely to promote financing for small and mid-sized companies. It goes without saying that AMAFI will remain very attentive and closely involved in the upcoming stages of this process.

Euro PP, a market standard Created in 2014, the Euro Private Placement has established itself as one of the tools used to facilitate access to market financing for small and mid-sized businesses by offering an alternative to bank loans. The Euro PP allows firms to borrow directly from a limited number of investors – or even a single investor – either in the form of a loan or, more commonly, a bond issue.To standardise and grow Euro PPs, AMAFI was heavily involved in marketwide initiatives that led to the publication of a Euro PP Charter in 2014 followed by two standard contracts (for loans and bonds respectively) in 2015. AMAFI also prepared a Code of Best Practice for Euro PP Arrangers (AMAFI/16-02) in 2016. The idea is to establish a market standard that underlines the key role played by arrangers in ensuring smooth and successful Euro PPs, thereby offering certainty to borrowers and investors that opt to take part in a Euro PP deal by calling on the services of an arranger that has promised to follow the code.The Euro PP steering committee, which brings together leading members of the financial community and in which AMAFI continues to play an active role, is moving ahead with efforts to grow this market. In this regard, the 2017 Euro PP conference, scheduled for 14 November at the Palais Brongniart in Paris as part of AFTE’s annual gathering, looks set to enjoy the same success as the two previous events.


Corporate bond market liquidityFollowing on from the study on liquidity published in late 2015 (AMAFI/15-48), AMAFI continued to track the many discussions being held on this topic. In August 2016, the International Organization of Securities Commissions (IOSCO) began a con-sultation on a draft report on the liquidity of corporate bond markets. AMAFI gave the report its full attention, not least because a key finding was the lack of evidence of a deteriora-tion in corporate bond liquidity, based on available data. AMAFI (AMAFI/16-44) argued that this assessment should be treated with care because it did not represent the view of market par-ticipants, pointing out that the IOSCO report even admitted that 68% of buy-side and 80% of sell-side survey respondents per-ceived liquidity to have decreased. Furthermore, some of the report’s supporting data were inappropriate: observation peri-ods were before 2014 in many cases, and an excessive share of data was taken from the US market. Most crucially, though, the report failed to recognise the atypical nature of the market situation owing to central banks’ non-standard monetary poli-cies. Particularly in Europe, these policies are creating a two-speed system with securities that are eligible for repurchase policies versus those that are not. Compounding these issues, the report considered liquidity only under normal market con-ditions and not when they deteriorate. These questions are now being discussed at European level within the expert group set up by the European Commission, which is expected to reach its conclusions in the second half of 2017.

Marketing structured productsBuilding on discussions first conducted in early 2015, the AMF announced at the start of 2016 that it wanted to establish a stricter framework for index-based structured products by updating its Position 2010-05. AMAFI made a number of pro-posals in this regard, seeking to take account of different types of indices, particularly proprietary indices, with the aim of ensur-ing they are understandable so that marketing can be adapted to suit retail investors. Since these proposals were not accepted, AMAFI submitted observations on the modifications proposed by the AMF, again to no avail (AMAFI/16-53), and Position 2010-05 (amended) was published in early 2017. AMAFI is currently holding discussions on the consequences of this, given that MiFID 2 and PRIIPs will enter into force in early 2018, establish-ing a harmonised framework designed to achieve the same objectives as the AMF position but by different means.

Remuneration for risk-takersThe applicable remuneration framework varies from country to country, particularly in terms of the ratio of fixed to variable remuneration (1:1 or 1:2 if authorised by the entity’s general meeting of shareholders). The European Commission would like to remove these variations. After conducting a consultation on this question in early 2016 (AMAFI/16-07), it proposed sev-eral amendments as part of the CRD 4 revision. During the lead-up to discussions on this legislation in the Council and Parliament, AMAFI highlighted (AMAFI/17-25) several concerns about the framework, whose legitimacy is based around the possibility that excessive variable remuneration might encour-age the emergence of systemic risk. It would be ironic if the first effect of the framework, applied across the board without regard to firm size, was to significantly increase fixed charges for many companies, as this would severely compromise their resilience given the highly cyclical nature of market activities. In other words, the effect would be the opposite of the frame-work’s legitimate goal. For this reason, AMAFI wants the pro-portionality principle to be fully applied.

Prudential requirements for investment firmsWork is underway on revising the prudential requirements aris-ing from CRD IV/CRR for investment firms. An EBA report in mid-December 2015 recommended a more proportionate approach for non-systemically important firms, which would be subject to less complex requirements, or, if they are very small firms, an extremely simplified regime based on fixed over-heads requirements. In the first half of 2016 AMAFI entered into discussions with the ACPR on this topic to prepare for the quantitative data exercise and consultation conducted by EBA at the end of the summer. The discussion paper published by EBA in early November 2016 proposes an original approach to measure the solvency of non-systemic investment firms, based not on the risk exposure of the investment firm but on the risk to which the investment firm would expose customers and the markets on which it operates in the event of its failure. EBA also left open the possibility of trimming and adjusting the existing regime for these firms, without clarifying the nature of the pro-posed amendments at this stage. While it wholeheartedly sup-ports the stated goals, AMAFI nevertheless pointed out (AMAFI/17-09) that the proposed solvency approach raised a number of difficulties that would be impossible to address sat-isfactorily in a sufficiently short space of time. Accordingly, AMAFI said that it would preferable and more practical to sim-plify and adapt the rules under the current regime and made a number of proposals to this effect. Several of AMAFI’s sister organisations in Europe also support this approach.

Last but not least…Throughout 2016 AMAFI kept a close watch on a number of other major policy areas, including the following:

20 AMAFI Annual Report 201620 AMAFI Annual Report 2016

Benchmarks Regulation AMAFI continues to closely follow efforts to prepare a Bench-marks Regulation, focusing particularly on the issue of discre-tionary indices. As part of this, it took part in the consultation held in February by ESMA based on a discussion paper (AMAFI/16-16). Following publication of the Benchmarks Reg-ulation in late June, ESMA organised a consultation on pro-posed RTS covering, among other things, the supervisory function, information to be published on benchmark method-ology and contributors’ governance and control procedures. AMAFI stressed the need to ensure that the proportionality principle is properly applied so that requirements are precisely calibrated to reflect the importance of the benchmarks in ques-tion (AMAFI/16-50). AMAFI also published a briefing memo on the regulation’s main provisions and how they apply to different index categories (AMAFI/17-23).

Anti-Money Laundering and Counter Terrorist Financing (AML/CFT)In a period of intense activity for AML/CFT, particularly in con-nection with transposition of the Fourth Anti-Money Laundering Directive, AMAFI’s AML/CTF Group kept up the collective effort in this area. Members met to learn about current regulatory projects, share practices and talk about issues encountered in the course of their duties. As part of the transposition process, which is now being completed, AMAFI flagged several issues for the Treasury (AMAFI/17-03), including the question of iden-tifying beneficial owners when the customer itself is a reporting entity from the financial sector or a public authority, for which streamlined due diligence is possible under a risk-based approach. This issue has a bearing on the efficient allocation of AML/CFT resources. AMAFI, along with two other industry groups, AFTI and AFG, sent a joint letter stressing this point to the Treasury.

Bond issuesThe Treasury held a consultation on draft proposals to reform French law on bond issues. The aim is to simplify and modern-ise the regulations to make them clearer and more attractive in order to facilitate market financing for companies. AMAFI expressed vigorous overall support for the proposals, which came largely out of cross-market work (AMAFI/17-16). It par-ticularly welcomed measures concerning the representation of bondholders, who will now be allowed to organise representa-tion in the issue contract for issues worth €100,000 and over. This will solve the shortcoming in the current regime for whole-sale transactions and notably for Euro PP transactions, which was identified from the outset of the marketwide work leading up to publication of the 2014 Euro PP Charter.

Ban on electronic advertisingThe Sapin 2 Act of 9 December 2016 contains a number of provisions that are especially meaningful for AMAFI members. One of these is a ban preventing investment services providers from directly or indirectly sending electronic communications of a promotional nature to retail customers, including prospects, if these communications concern investment services involving speculative financial contracts (AMAFI/16-60). The AMF had lobbied hard for this ban after French retail investors were scammed by Cypriot ISPs operating under European pass-ports. Ahead of the measure’s adoption, the AMF launched a public consultation in early August on a draft amendment to its General Regulation aimed at specifying the banned categories of contracts based on the criteria set down in the legislation. In the end, the AMF adopted several of AMAFI’s proposals (AMAFI/16-41) in the final framework. Furthermore, in accord-ance with AMAFI’s wishes and after consultation (AMAFI/16-60), the AMF rounded out the framework in January 2017 with a policy instrument in the shape of a Q&A covering three areas: affected financial contracts, communications subject to the framework, and sponsorship activities. This document will probably be expanded between now and the summer to accommodate internet-specific issues.

PROFILE


AMAFI

AMAFI’s work extends to all activities on regulated, unregulated, primary and secondary financial markets for both cash and derivative products.

Serving market professionals since 1988AMAFI has represented financial market professionals since 1988, making active con-tributions to the many consultations and reforms that continually transform financial markets and helping its members to adjust to new developments. AMAFI is now the principal forum for the collective efforts of financial market professionals operating in France, representing 140 member firms at 1 June 2017. AMAFI’s member firms are directly involved in the financial markets (intermediaries, banks, infrastructures) and include independent companies and subsidiaries of French and foreign groups operating in all areas of the industry (broking, dealing, underwriting, corporate finance, etc.) and all products (equity, debt and derivatives, including commodities). To reach out beyond this natural constituency and bring together all parties involved in growing the Paris financial centre, AMAFI has expanded its Correspondent Member category to include law firms and consultancies that are active in market-related questions.AMAFI has evolved naturally to keep pace with changes in an environment that has become largely European and international rather than simply domestic. One of the phases that embodied that evolutionary process came in 2008 with a change of name, from the French Association of Investment Firms (AFEI) to AMAFI. The aim was to clearly mark the fact that the organisation carries out its activities on behalf of all market par-ticipants, whatever their operational status.

Our task: representing market participants in FranceAMAFI plays an active part in shaping the domestic, European and international regulations that form the framework in which our members operate. It does this by conveying the industry’s views and opinions to the relevant institutions and authorities. It also fosters collective analysis and informs members about issues of common interest. And it leads the public debate over the economic and social role played by the markets by providing input from the firms that it represents.To discharge its tasks, AMAFI works closely with its members through standing commit-tees and working groups. To enhance our effectiveness, we are also committed to coor-dinating our efforts with other industry participants in France and with our sister organi-sations abroad.

AMAFI milestones1988: Founded as Association française des sociétés de bourse (Afsb).

1996: Becomes Association française des entreprises d’investissement (Afei) and joins Association française des établissements de crédit et des entreprises d’investissement (Afecei).

2008: Changes name to AMAFI.

AMAFI positions express a collective viewpointTo be effective, we need a precise understanding of our members’ wants and needs. We therefore proceed in three stages:

> Our staff identify the major points they believe require attention.

> This initial approach is honed by drafting a working paper setting out AMAFI’s position. The paper is produced by our members in the standing committees and working groups.

> The working paper is submitted to the Board or the Executive Committee for approval before being forwarded to the relevant bodies and sent out to members.

The three main types of document issued by AMAFIProfessional standards apply to the entire industry. Implementation can therefore be supervised by the competent authority or authorities. For this reason, adopting a professional standard is a complementary or alternative solution to action by the public authorities and regulators.

Professional best practices establish a recognised means of implementing a legal or regulatory obligation. They do not preclude the use of other equivalent – or more stringent – means of implementation.

Professional recommendations provide an interpretation or means of implementing a legal or regulatory obligation.

Association française des marchés financiers (AMAFI) represents professionals working in the securities industry and financial markets in France. Reflecting the diversity of firms and activities involved in the sector, AMAFI generates ideas and analyses for an industry that plays a vital role in financing economic activity, allocating savings and supporting growth.


2017 Turgot Prize for the book Plus de marché pour plus d’État !

Seek the regulatory solutions that best fit our members’ needsFinancial market activities are increasingly heavily regulated, and the need for far-reach-ing reforms in the light of lessons learned from the crisis has given fresh impetus to this trend. When new laws and regulations are being drafted at domestic, European or international level, AMAFI seeks and promotes solutions that address its members’ needs and expectations, while taking account of the stated regulatory objectives. It voices the opinions of the professionals it represents, ensuring in particular that their business is not unduly restricted. Although the standards governing the financial industry are now chiefly European, in some cases based on principles adopted at international level, the functions of oversight and sanction are still carried out at domestic level. In consequence AMAFI is active at all these different levels. At the domestic level, our main talking partners are the Treasury, the securities regulator, AMF, and the prudential over-sight and resolution authority, ACPR. AMAFI is also active at the European and interna-tional levels. Its many institutional contacts include the European Commission, the Euro-pean Securities and Markets Authority (ESMA), the International Organization of Securities Commissions (IOSCO) and the Financial Action Task Force (FATF). To take its activities forward at this supranational level, AMAFI and its counterparts have created two venues for discussion and coordination: the International Council of Securities Asso-ciations (ICSA) and the European Forum of Securities Associations (EFSA). AMAFI has also been an associate member of the Futures Industry Association (FIA) since 2007.

Initiating research and debate on issues of common interest and informing our membersAMAFI is a forum for discussing and examining all the issues that are of common interest to our members. In particular, we provide them with analytical tools that help them to position themselves strategically with respect to changes in the operating environment. To that end, AMAFI prepares professional standards for fields of activity that interest our members, such as the code of conduct for liquidity contracts. We also prepare and cir-culate memorandums setting out the industry position on issues and queries that have been referred to us, in the form of professional best practices or professional recommen-dations, such as the AMAFI-FBF Implementation Guide on procedures for reporting sus-picions of market abuse, or the standard liquidity contract.AMAFI keeps members up to date on developments and trends affecting their operating environment. We comment on the major statutes and regulations which impact on that environment, analysing the key issues from our members’ perspective. AMAFI also holds conferences, often in partnership with other organisations, that focus on specific questions of member interest, usually topics of current interest, such as MiFID 2 (cf. page 14).

Giving financial professionals a say in public debateIn France, although the criticism has died down somewhat, the usefulness of financial markets continues to be frequently called into question. Yet the markets play a key role in financing economic activity, a function made more important by the adoption of new prudential standards.For that reason, AMAFI’s communication efforts hinge on helping the public at large to understand the role that financial markets play and how they are useful both to society and to the economy. With this in mind, AMAFI is endeavouring to speak out more vocally and take an increasingly prominent part in the public debate on the role of financial markets.

International Council of Securities Associations – ICSA AMAFI is a founder member of ICSA. Founded in 1989, the council is a forum for international cooperation and coordination. Members exchange information, discuss topics of common interest and lobby to promote their views. Pierre de Lauzun sits on the committee which functions as ICSA’s Management Committee . During ICSA General Meeting, hold in Mexico in may 2017, Pierre de Lauzun has been elected Chair of ICSA.

European Forum of Securities Associations – EFSAAMAFI, along with Assosim (Associazione Italiana Intermediari Mobiliari), LIBA (now part of the Association for Financial Markets in Europe, AFME), and SSDA (Swedish Securities Dealers Association), co-founded this body in early 2007. A forum for cooperating on and talking about the shared issues facing European financial market participants, EFSA has grown to include associations from Spain, Denmark, Germany, Italy and Poland.

Published by Revue Banque and Eyrolles, with the assistance of AMAFI, Plus de marché pour plus d’État ! won the 2017 Turgot Prize for best book on financial economy, presented by Minister for the Economy Michel Sapin. Co-written by Philippe Tibi, honorary chairman of AMAFI, founder of Pergamon Campus and professor at École polytechnique, and Francis Kramarz, head of the Centre de recherche en économie et statistique (CREST) and professor at ENSAE and École polytechnique, with a forward by Emmanuel Macron, this book takes an original look at the state/market relationship. Drawing on real-life examples from labour, housing and innovation, the authors show that the state needs to use the market in order to better fulfil its role as the guardian of social cohesion.


One way it is doing this is by working with publishers and media partners to release books and special issues. AMAFI has co-published 11 special issues of Revue Banque (RB) magazine since 2011. Each of these issues has sought to fuel the discussion around a given topic through contributions by prominent personalities from a wide range of back-grounds (see box). In 2012, AMAFI teamed up with publishers RB and Eyrolles to release Les marchés font-ils la loi ?, a book of interviews with Philippe Tibi (then AMAFI Chairman) and Pierre de Lauzun (Chief Executive) that considers whether markets dictate policies. This was followed in 2016 by Plus de marché pour plus d’État !, a new essay authored by Philippe Tibi and Francis Kramarz, which won the Turgot Prize for best book on the financial economy in March 2017 (see box for more). At the end of 2017 AMAFI plans to release a book written by staff about MiFID 2, again in partnership with RB.Pierre de Lauzun also regularly gives his perspective on topical issues in opinion pieces posted on the open forum area (Le Cercle) of the echos.fr website. Recent contributions include pieces on Brexit and the French presidential elections. AMAFI has forged strong ties not only to the financial press, but also to mainstream newspapers. These efforts are bearing fruit: with over 250 articles citing AMAFI in 2016, we are now a recognised authority on market-related questions.Also, in 2010, AMAFI formed a Scientific Advisory Board made up of economists, aca-demics, journalists and practitioners.

Assisting members individuallyAlthough our role does not involve acting as an outside consultant, AMAFI can help mem-bers tackle individual issues from time to time. Our aid is essentially confined to providing guidance, unless the question is one that turns out to concern all members. Unsurprisingly, most of the calls for help concern legal, tax and ethics issuesFurthermore, though not acting in lieu of a law firm, AMAFI does accept requests from members for assistance with proceedings brought against them. This may involve disci-plinary proceedings or controls ordered by the ACPR or the AMF. It may also involve disputes arising from tax inspections, which are heard by a Tax Commission at local or national level, on which AMAFI is entitled to sit as a taxpayers’ representative.In each situation, AMAFI tries to help the member by providing a collective viewpoint.

An employment framework for the industry: the CCNMAs the representative of employers in management/union discussions, AMAFI is a signatory of the national collective bargaining agreement for financial market activities (CCNM), which governs employer/employee relations for a number of its members.

Joint CommissionComposed of representatives of employers and employees, the Joint Commission may be asked to interpret issues relating to the collective agreement, to mediate in collective disputes, to approve in-house agreements in firms with no trade union rep-resentatives, and to issue an opinion in the event of dismissal for gross or wilful neg-ligence and discrimination against trade unions. Three cases were brought before the Commission in 2016.

AMAFI partnership with Revue BanqueThe most recent special issue of Revue Banque magazine, published in June 2017, takes a look at sovereign wealth funds (SWFs), examining the role of the State as an investor and strategist on financial markets through SWFs and other similar vehicles. It sheds light on the wide variety of structures set up by central governments, their benefits for the national economy in terms of returns, macroeconomic goals and geopolitical strategy, and their share of financial markets.

The previous special issue, in December 2016, spotlighted questions within the finance community about how and why ethics should be applied to banking and the markets, and considered how to reach common definitions for concepts of ethics or morality. The article presented contrasting views from researchers and testimonials from bankers on the role of ethics in finance. It addressed such questions as: How should ethics be defined? How should ethical principles be applied to financial market activities and firms? Can ethics be a part of “good finance”?

A lecture and discussion session was organised for each publication, attracting more than 200 people each time.

Professional liability insurance AMAFI offers members a master insurance policy providing a broad range of coverage and deductible choices and many other options to enable members to protect themselves effectively against business risks such as professional liability, fraud/ embezzlement and computer abuse. The policy is managed by AON.

Skill level: executive and managerial staff were steady at 75% of the total sector workforce. Employees in Category III.A accounted for 65% of the workforce.

Employment Intelligence Unit 2015The Employment Intelligence Unit reviewed the data gathered from member firms for 2015 at its meeting on 8 December 2016.

Women in the workforce: the percentage of women in the industry was more or less unchanged compared with previous years, at 40% of the total in 2014 and 2015.

Age : average age in the sector was slightly higher, at 39. Over the 2004/2015 period, the sector workforce aged overall: the share of those in the 30-39 bracket declined while the share of over-40s increased from just over 37% of the workforce in 2004 to over 46% in 2015. However, a rejuvenation process is underway, with the 20-29 bracket growing its share from 18.11% in 2004 to 22.47 %.

Age

18

100

2022242628303234363840424446485052545658606264666872

50 0 50 100

WomenMen

Skill level80%

70%

60%

50%

40%

30%

20%

10%2%

Other

0%

7%

IA

4%

IB

5%

IIA

7%

IIB

65%

IIIA

7%

IIIB

3%

IIIC


Length of service

More than 35 years 0.16%

0 - 5 years 48.37%

5 - 14 years33.22%

15 - 24 years 14.62%

25 - 34 years 3.62%

Length of service: average length of service increased slightly, particularly in the 15 years and over brackets.


L’Info AMAFIPublished every two months, L’Info AMAFI summarises the key issues that AMAFI is working on at national, European and international levels. A feature article deals in depth with a topical aspect of financial market business. L’Info AMAFI is written not only for our members but also for our regular talking partners – parliamentarians, ministries, the Treas-ury, supervisors – to alert them to matters of specific interest to member activities and operations.

AMAFI Financial NewsletterAMAFI Financial Newsletter is published in English three times a year and emailed to readers in Europe and elsewhere in the world. Organised around a feature article covering a current domestic or international theme, it provides an overview of AMAFI’s main activities in areas of interest to readers outside France. AMAFI launches its new website AMAFI new website www.amafi.fr will be launched in June 2017. The new look is designed to make the site more accessible and reader-friendly. The overall framework remains the same, however. Visitors to the public section can find information about AMAFI and its members, tasks, projects and positions. The restricted section gives members full access to AMAFI’s library of analytical memos, position papers, briefing memos, consultation responses and more. It also provides a dedicated working area for committee members.

AMAFI uses its media tools to raise the profile of its activities and policies in order to serve the market participants it represents.

AMAFI’s partnership with the Musée d’Orsay and the Musée de l’OrangerieAMAFI has teamed up with the Musée d’Orsay and the Musée de l’Orangerie to set up a corporate sponsor club for financial sector companies looking to support the institutions’ projects. The Cercle Mécénat et Finance provides valuable support to educational initiatives (notably aimed at young or disabled people) and heritage projects (restorations, acquisitions) proposed by the two museums.

AMAFI on Twitter Tweets posted at @AMAFI_FR draw attention to opinion pieces, interviews, press releases and other pronouncements and spread the word about events such as conferences and launches. @AMAFI_FR

Our media tools

© Musée d’Orsay/S. Boegly


Standing committeesCommodities Committee Chair Haroun Boucheta

SOCIÉTÉ GÉNÉRALE

Rapporteur Véronique Donnadieu

Béatrice Ambrosi SOCIÉTÉ GÉNÉRALE

Elisabeth-Anne Bertin EDF

Olivier Beyne ODDO et Cie

Jeanine Busserrolle CACEIS Corporate Trust

Antoine Chacun ODDO et Cie

Olivier Coupard CRÉDIT AGRICOLE CIB

Jessica Deboeck ENGIE GLOBAL MARKETS

Delphine Feyrit LCH. SA

Guillaume Fouchères EXANE

Marc Giannoccaro CACEIS CORPORATE TRUST

Florence Hillaire SOCIÉTÉ GÉNÉRALE

Nicholas Kennedy EURONEXT

Marc Lacroix ODA FUTURES

Nicolas Mercier CIC

Didier Nedelec ODA FUTURES

François de Neuville BNP PARIBAS

François-Xavier Olivieri ENGIE GLOBAL MARKETS

Priscilla Paillard ENGIE GLOBAL MARKETS

Lionel Porte EURONEXT

François-Xavier Poupon SOCIÉTÉ GÉNÉRALE GBIS

Jérôme de Preneuf AUREL BGC

Olivier Raevel EURONEXT PARIS

Élie de Richemont CACEIS Corporate Trust

Compliance Committee Chair Étienne Valence

BNP Paribas

Rapporteur Pauline Laurent

Magali Arrivé BARCLAYS BANK PLC France

Jean-Nicolas Barbier GOLDMAN SACHS PARIS INC & Cie

Florence Bastide BARCLAYS BANK PL France

Olivier Beyne ODDO et Cie

Phoebus Boissel JP MORGAN

Alain Bruneau NATIXIS

Vincent Carrasset HSBC France

Henri Casadesus MORGAN STANLEY & Co International PLC

Aurélie Cauche NATIXIS

Thierry Cazaux AUREL BGC

Yann Célérier SOCIÉTÉ GÉNÉRALE

Pierre-Emmanuel Charrette ODDO et Cie

Agnès de Clermont Tonnerre UBS Securities France SA

Édouard Cochet BNP PARIBAS

Delphine Colombel CITIGROUP GLOBAL MARKETS Limited

Charlotte Fantauzzo HSBC France

François Gautron NATIXIS ASSET MANAGEMENT FINANCE

Thierry Georges CRÉDIT AGRICOLE SA

Fabienne Larroque BNP PARIBAS

Xavier de La Maisonneuve EXANE

Jean Martinelli STANDARD CHARTERED BANK

David Morlier BANQUE NOMURA France

Sophie Mourton UBS Securities France SA

Aude Oberrieder UNICRÉDIT BANK AG

Bruno Pabst TRADITION SECURITIES AND FUTURES

Raphaël Penas Murillo CITIGROUP GLOBAL MARKETS LIMITED

Roland de la Tullaye RAYMOND JAMES EURO EQUITIES

Anne Roullet TSAF OTC

Olivier Roussin BANK OF AMERICA MERRILL LYNCH International Ltd

Didier Serie SOCIÉTÉ GÉNÉRALE

Paola Sudaro SOCIÉTÉ GÉNÉRALE

Thierry Villie EXANE

Camille Wu AXA INVESTMENT MANAGERS IF


Tax Committee Chair Emmanuel Strauss

NATIXIS

Rapporteur Éric Vacher

Pierre Bacqué KEPLER CHEUVREUX SA

Sébastien Beaufre MORGAN STANLEY & Co International PLC

Catherine de Bettignies BNP PARIBAS Arbitrage SNC

Christophe Bonnabry SOCIÉTÉ GÉNÉRALE

Nathalie Brunet CIC

Pierre-Ollivier Cohen UBS SECURITIES France SA

Daniel Djibré ODDO et Cie

Amélie Dromain DEUTSCHE BANK AG Succursale de Paris

Vincent Fleuret EXANE

Alexandra Follorou NATIXIS

Alain Gouérec DEUTSCHE BANK AG Succursale de Paris

Jean-Olivier Huynh CRÉDIT AGRICOLE SA

Longo-Joseph Kouloumba SOCIÉTÉ GÉNÉRALE

Thomas Lansac BANQUE NOMURA France

Nathalie Léonard HSBC BANK PLC Paris Branch

Rozenn Louvel PROCAPITAL

Nicolas Meunier HSBC BANK PLC Paris Branch

Anne-Marie Michon CIC

Stéphanie Monnais-Michel CACEIS CORPORATE TRUST

Claude Moysan Messager BNP PARIBAS

Valérie de Pontbriand LYXOR INTERMEDIATION

Laurence Willig EXANE

Legal Committee Chair Pierre-Vincent Chopin

BNP PARIBAS

Rapporteur Sylvie Dariosecq

Virginie Amico EXANE DERIVATIVES

Valentine Aquilina SOCIÉTÉ GÉNÉRALE GBIS

Philippe Arestan CRÉDIT AGRICOLE CIB

Magali Augereau J.P. MORGAN SECURITIES Ltd

Jean-Nicolas Barbier GOLDMAN SACHS PARIS INC & Cie

Stéphanie Bianco EXANE DERIVATIVES

Jean-Pierre Blin FORTUNÉO BANQUE

David Bourel HSBC France

Bertrand Bréhier SOCIÉTÉ GÉNÉRALE

Henri Casadesus MORGAN STANLEY & Co International PLC

Olivier Chomette NATIXIS

Audrey Dahan BNP PARIBAS

Marie-Clotilde Defives ROTHSCHILD & Cie BANQUE

Cécile Degove CDC PLACEMENT

Radia Djama NATIXIS ASSET MANAGEMENT Finance

Sophie Drion NATIXIS

Hélène Ducrocq EDMOND DE ROTHSCHILD France

Laurent Durand HSBC France

Richard Exbrayat BNP PARIBAS

Andreja Fajgelj CITIGROUP GLOBAL MARKETS Limited

Anne Favé LCH. SA

Pierre Fiset CITIGROUP GLOBAL MARKETS Limited

Romain Garnier ODDO et Cie

Fabienne Golias FORTUNÉO BANQUE

Hager Hidri BINCK BANK

Laurent Lorgeré ROTHSCHILD & Cie BANQUE

Jean Martinelli STANDARD CHARTERED BANK

Olivier Mittelette FEDERATION BANCAIRE FRANÇAISE

David Morlier BANQUE NOMURA France

Éric Paillot CIC

Fanny Palmieri EUROCLEAR France

Claire Pons-Henry NATIXIS Asset Management Finance

Olivier Sabourin SOCIÉTÉ GÉNÉRALE

Patricia Salomon EDMOND DE ROTHSCHILD France

Patrick Trossat CIC

Collective Bargaining Commission Chair Jean-Bernard Laumet

Rapporteur Alexandra Lemay-Coulon

Olivier Brot ODDO et Cie

Mathieu Caron EURONEXT PARIS

Isabelle Cocquart MOSAIC FINANCE

Christian Fine Personnalité qualifiée

Alain Le Bohec Personnalité qualifiée

Patrick Portais BNP PARIBAS Arbitrage SNC

> AML/CFT> Benchmark indices> Euro PP> Financial analysis> French financial transaction tax and AFME protocol> Index Guide> Investment recommendations> Investment services – Scope> Liquidity contracts> Major shareholding notifications> Market abuse> Market soundings> MiFID 2 – Automated trading> MiFID 2 – Commodities Q&A> MiFID 2 – Costs and expenses> MiFID 2 – Product governance> MiFID 2 – Project managers> MiFID 2 – Research financing> MiFID 2 – Territoriality> MiFID 2 – Trade reporting> PRIIPs> Private banking compliance> Programmed trading mandate> Prudential treatment of investment firms> Structured products

Working groupsIn addition to its 9 standing committees, AMAFI relies on 25 working groups, each specialising in a topical issue, to carry its action forward.


Corporate Finance Committee Chair Florence Gréau

SOCIÉTÉ GÉNÉRALE GBIS

Rapporteur Sylvie Dariosecq

Valéry Barrier CITIGROUP GLOBAL MARKETS LIMITED

Philippe Cassagnes CIC

Stéphane Courbon BANK OF AMERICA MERRILL LYNCH International Ltd

Laurent Durand HSBC France

Laurent Durieux KEPLER CORPORATE FINANCE

Elsa Fraysse ROTHSCHILD & Cie BANQUE

Charles-Henri Gaultier DEUTSCHE BANK AG Succursale de Paris

Adeline de Jaeghere BANK OF AMERICA MERRILL LYNCH International Ltd

Angélique Jouanne SOCIÉTÉ GÉNÉRALE GBIS

Éric de Lacroix Vaubois ROTHSCHILD & Cie BANQUE

Gauthier Le Milon BNP PARIBAS

Frédéric Lorin BNP PARIBAS

Olivier Mougeotte CREDIT AGRICOLE CIB

Françoise Negroni NATIXIS

Françoise Poujetoux-Bourzeix CREDIT AGRICOLE CIB

Cyril Revenu HSBC Bank PLC Paris Branch

Vincent Rietzler ODDO et Cie

Small, Medium and Mid-Market Companies Committee Chair Éric le Boulch

CIC

Rapporteur Emmanuel de Fournoux

Hubert Brac de La Perrière EXANE

Jean-René de Fraguier ODDO et Cie

Eric Forest ENTERNEXT

Florence Gréau SOCIÉTÉ GÉNÉRALE GBIS

Marc-Antoine Guillen INVEST SECURITIES

Vincent Le Sann PORTZAMPARC SOCIÉTÉ DE BOURSE

Pascal Mathieu GILBERT DUPONT SNC

Philippe de Portzamparc PORTZAMPARC SOCIÉTÉ DE BOURSE

Damien Rahier PORTZAMPARC SOCIÉTÉ DE BOURSE

AMAFI–AFTI Markets Committee Post-Trade Chair Emmanuel de Fournoux

Rapporteur Ivan Takahashi COGNIZANT BUSINESS CONSULTING SAS

Myriam Aouam NATIXIS

Sylvie Bonduelle SOCIÉTÉ GÉNÉRALE SECURITIES SERVICES

Jocelyn de Bourmont SOCIÉTÉ GÉNÉRALE GBIS

Marc-Antoine Bourdet UBS SECURITIES France

Jean de Castries COGNIZANT BUSINESS CONSULTING SAS

Patrick Crésus EXANE

Caroline Derocle EUROCLEAR France

Géraldine Goursaud BNP PARIBAS SECURITIES SERVICES

Guy de Leusse ODDO et Cie

Frédéric Mesnière CIC

Gildas Le Treut ABN AMRO CLEARING

Fabrice Novel CITIBANK INTERNATIONAL PLC PARIS BRANCH

Pierre-Dominique Renard LCH. SA

Christian Simonet EURONEXT

Eric Rettien KEPLER CHEUVREUX

Market Structure Committee Chair Stéphane Giordano

SOCIÉTÉ GÉNÉRALE GBIS

Rapporteur Emmanuel de Fournoux

Haroun Boucheta SOCIÉTÉ GÉNÉRALE

Arnaud de Bourrousse OCTO FINANCES SA

Thierry Cazaux AUREL BGC

Nathalie Gay-Guggenheim HSBC France

Pauline Guérin FÉDÉRATION BANCAIRE FRANÇAISE

Alain Gouérec DEUTSCHE BANK AG Succursale de Paris

Arnaud Grandamy OCTO FINANCES SA

Lucile de La Jonquière CRÉDIT AGRICOLE CIB

Christophe Kieffer AMUNDI INTERMEDIATION

Caroline Kostra CRÉDIT SUISSE SECURITIES EUROPE Limited

Nicolas Mercier CIC

Olivier Mittelette FÉDÉRATION BANCAIRE FRANÇAISE

François de Neuville BNP PARIBAS

Catherine Nicand NATIXIS

Vincent Remay TRADITION SECURITIES AND FUTURES

Christian Simonet EURONEXT

Philippe de Soumagnat SOCIÉTÉ GÉNÉRALE GBIS

Sébastien Yousri NATIXIS


There are three membership categories: Direct Member, Associate Member and Correspondent Member. For more information on joining and a description of all three categories, visit www.amafi.fr, and go to the “AMAFI” section.The choice of category depends on the role the applicant wants to play in AMAFI’s activities and is subject to Board approval. Firms that are required by law to belong to an AFECEI- affiliated association and are fulfilling this obligation by joining AMAFI must opt for Direct Member status.Law firms and consultancies working to promote market activities within the Paris financial centre may apply to be admitted as Correspondent Members.

Our membersAt 1 June 2017 AMAFI had 140 members, including investment firms, credit institutions, trading and post-trade infrastructures, legal firms and consultancies.

Membership analysis1 June 2017

Analysis of direct members by headcount bracket30 June 2016

0 - 10employees30

11 - 50employees31

More than 501employees5

51 - 150employees

15

151 - 500 employees

9

DirectsMembers88

CorrespondentMembers

31

AssociateMembers

21


A ALLEN & OVERY** AMUNDI INTERMEDIATION ARFINCO ARKÉA DIRECT BANK SA ASHURST LLP** AUREL BGC AXA ÉPARGNE ENTREPRISE AXA INVESTMENT MANAGERS IF AXELTIS

B B*CAPITAL BANQUE NEUFLIZE OBC* BANQUE NOMURA France* BANQUE PALATINE** BANQUE PRIVÉE 1818* BARCLAYS BANK PLC, CIB BINCK BANK BNP PARIBAS ARBITRAGE SNC BNP PARIBAS DEALING SERVICES BNP PARIBAS SECURITIES SERVICES* BOURSE DIRECT BPCE* BRED BANQUE POPULAIRE*

C CA INDOSUEZ WEALTH* CACEIS CORPORATE TRUST CARAX SA CDC PLACEMENT CIC CID CONSULTING** CITIGROUP GLOBAL MARKETS Ltd* CLARESCO BOURSE CM – CIC ÉPARGNE SALARIALE CLIFFORD CHANCE EUROPE LLP** CMC MARKETS UK PLC** CMS BUREAU FRANCIS LEFEBVRE** COGNIZANT BUSINESS CONSULTING SAS** COMPAGNIE FINANCIÈRE JACQUES CŒUR COPARTIS CRÉDIT AGRICOLE CIB CRÉDIT AGRICOLE SA* CRÉDIT AGRICOLE TITRES CRÉDIT MUTUEL ARKÉA* CRÉDIT SUISSE (Luxembourg) SA Succursale en France

D DE PARDIEU BROCAS MAFFEI** DESCARTES TRADING DEUTSCHE BANK AG Succursale de Paris* DEXIA CRÉDIT LOCAL*

E EASY BOURSE EDF* EDMOND DE ROTHSCHILD France* ENGIE GLOBAL MARKETS EOS VENTURE EPEX SPOT SE** EQUITIM EUROCLEAR France* EURONEXT PARIS EXANE EXANE DERIVATIVES EXCLUSIVE PARTNERS EXOE SAS

F

FIDAL** FINAVEO et Associés FRESHFIELDS BRUCKHAUS DERINGER** FUNDQUEST ADVISOR

G

GALAXY SAS GFI SECURITIES LIMITED** GIDE LOYRETTE NOUEL** GILBERT DUPONT SNC GOLDMAN SACHS PARIS INC & Cie GROUPAMA ÉPARGNE SALARIALE

H

HPC HSBC BANK PLC PARIS BRANCH HUGHES HUBBARD & REED LLP**

I

INSTINET Europe Limited INTER EXPANSION - FONGEPAR INVEST SECURITIES INVESTIMO*

J

J.P. MORGAN SECURITIES Ltd JOH BERENBERG Gossler & Co, KG** JONES DAY**

K

KEPLER CHEUVREUX SA KRAMER LEVINE NAFTALIS & FRANKEL LLP**

L

LA FRANÇAISE BANK, Succursale de Paris LCH SA LCL-LE CREDIT LYONNAIS* LEONTEQ SECURITIES (Europe) GmbH** LINKLATERS** LOMBARD ODIER EUROPE SA (Succursale en France) LOUIS CAPITAL MARKETS UK LLP LYXOR INTERMÉDIATION

M

MAINFIRST BANK AG PARIS BRANCH* MARIGNY CAPITAL MAZARS Société d’avocats** MERRILL LYNCH CAPITAL MARKETS FRANCE SAS* MIRABAUD & CIE (Europe) SA MORGAN STANLEY France* MOSAIC FINANCE MTS France

N

NATIXIS NATIXIS ASSET MANAGEMENT FINANCE NEXO CAPITAL SAS NORTIA INVEST NORTON ROSE FULBRIGHT LLP**

O

OCTO FINANCES SA ODA FUTURES ODDO et Cie ODDO CONTREPARTIE OFI INVESTMENT SOLUTIONS** ONE POINT** OPERA TRADING CAPITAL ORIENT FINANCE OTCex SA

P PORTZAMPARC SOCIÉTÉ DE BOURSE POWERNEXT SA PRADO ÉPARGNE PROCAPITAL PROREALTIME SAS PwC SOCIÉTÉ D’AVOCATS**

R RAYMOND JAMES EURO EQUITIES REGARD BTP ROTHSCHILD & CIE BANQUE

S SAXO BANQUE SELECTION 1818 SG OPTION EUROPE SICAVONLINE SA SIMMONS & SIMMONS** SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP** SKANDIA INVEST SA SOCIÉTÉ DE BOURSE PAREL SA SOCIÉTÉ GÉNÉRALE SPITZ & POULLE AARPI** STANDARD CHARTERED BANK* STATE STREET BANQUE SA**

T TAJ SOCIÉTÉ D’AVOCATS** TRADITION SECURITIES AND FUTURES TSAF OTC

U UBS Limited – Succursale de France UBS SECURITIES France SA UNICREDIT Bank AG

W WHITE & CASE** WISEED

* Associate members** Correspondent members


Industry bodiesAssociation Française des Établissements de Crédit et des Entreprises d’Investissement – AFECEIStéphane Giordano, AMAFI Chairman, is Vice-Chairman of AFECEI

Comité Consultatif de la Réglementation et de la Législation Financière – CCLRF Sylvie Dariosecq (AMAFI) represents investment firms. Her alternate is Bertrand de Saint Mars (AMAFI).

Comité Consultatif du Secteur FinancierPauline Laurent (AMAFI).

ORIAS – Commission d’immatriculation au registre unique des intermédiaires (Commission for Registration in the Single Register of Intermediaries)Sylvie Dariosecq (AMAFI).

ACPR Consultative CommissionsEmmanuel de Fournoux (AMAFI) on the Consultative Commission on Prudential Affairs – Pauline Laurent (AMAFI) and Blandine Julé (AMAFI) on the Consultative Commission on the Prevention of Money Laundering and Terrorist Financing.

AMF Consultative CommissionsBertrand de Saint Mars (AMAFI) on the Consultative Commission on Markets and Exchanges and Emmanuel de Fournoux (AMAFI) on the Consultative Commission on Clearing, Custody and Securities Settlement.

Comité de Place Euroclear France Emmanuel de Fournoux (AMAFI).

Employment-related bodiesComité Interentreprises de la Bourse (Intercompany works council for the securities industry, CIE)Jean-Bernard Laumet, CIE Chairman (Vice-Chairman, AMAFI), Jean-Pierre Allot, CIE Vice-Chairman (retired) and Alexandra Lemay-Coulon (AMAFI).

Humanis Retraite Agirc, a supplementary retirement scheme for executive staff Alexandra Lemay-Coulon (AMAFI) is a director and member of the finance commission.

GIE Assurance de personnes / personal insuranceAlexandra Lemay-Coulon (AMAFI), director.

Humanis Prévoyance Alexandra Lemay-Coulon (AMAFI) is Vice-Chair and member of the finance and risk commission and the employment commission.

Humanis Développement Solidaire (social protection insurance group company) Alexandra Lemay-Coulon (AMAFI) is a director and member of the finance and risk commission

Mutuelle Humanis Nationale Jean-Pierre Allot (retired), director.

Adéis (joint group providing personal risk solutions for different industries)Alexandra Lemay-Coulon (AMAFI), director.

External bodies in which AMAFI is involved

In addition, delegates from AMAFI’s Board and staff, as well as members, represent AMAFI on bodies such as Paris Europlace, the French Business Confederation (MEDEF), the French Banking Federation (FBF) Association Française des Professionnels du Titre (AFTI), a post-trade industry group, and the French Treasury.

Director of publication Bertrand de Saint Mars

Chief editor Philippe Bouyoux

Designed, edited and produced by Anne Béchiri & Raphaël Thomas

06 89 08 77 66English adaptation

VO Paris June 2017

13, rue Auber – F-75009 Paris – FrancePhone: + 33 1 5383-0070 – Fax: + 33 1 5383-0083

www.amafi.fr – E-mail: [email protected]

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