FCA Consultation Paper on Proposals to Improve Shareholder Engagement

Published on:
March 27, 2019
Submitted to:
Financial Conduct Authority
Submitted by:
SIFMA AMG

Summary

SIFMA AMG provided comments to the Financial Conduct Authority on the FCA’s Consultation on proposals to improve shareholder engagement which sets out how parts of the Revised Shareholder Rights Directive are proposed to be implemented in the UK.

This comment letter primarily responds to the proposals within the Consultation regarding the requirements that would apply to asset managers and institutional investors. It does not address the proposed changes to the requirements for companies whose shares are admitted to trading on a regulated market in the UK.

Excerpt

David Stubbs

Primary Markets Policy

Financial Conduct Authority

12 Endeavour Square

London E20 1JN

Re: FCA Consultation Paper on Proposals to Improve Shareholder Engagement.

Dear Sirs:

The Asset Management Group (the “AMG”) of the Securities Industry and Financial Markets Association (“SIFMA”) appreciates the opportunity to provide comments to the Financial Conduct Authority (“FCA”) on the FCA’s Consultation on proposals to improve shareholder engagement (the “Consultation”),1 which sets out how parts of the Revised Shareholder Rights Directive (“SRD II”)2 are proposed to be implemented in the UK.

The AMG is the voice for the buy side within the securities industry and broader financial markets, which services millions of individual and institutional investors as they save for retirement, education, emergencies, and other investment needs and goals. AMG’s members comprise U.S., UK and multinational asset management firms with combined global assets under management exceeding $45 trillion. The clients of AMG member firms include, among others, tens of millions of individual investors, registered investment companies, endowments, public and private pension funds, UCITS, and private funds such as hedge funds and private equity funds.

While our members operate both inside and outside the United States and many are considered to be global enterprises, the background and orientation of our organization is rooted in U.S. laws and regulations, and our letter reflects our familiarity with such laws and regulations.

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