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Summary Report of the 17 Responses to the CMVM Sustainable Finance Reflection and Consultation Document


The CMVM today released a summary report of the responses to the Reflection and Consultation Document on Sustainable Finance published in February 2019 which was answered by 17 entities, including the main associations representing the business and financial and consumer sectors, including several companies. 
 
Both documents and the responses, now available on the CMVM website, are a milestone in the national approach to Sustainable Finance. On the one hand, one is able to know, at an early stage, the national financial sector's integration of ESG factors, including the ​market regulator's standpoint; and on the other, they identify the challenges of increasing integration of practices and instruments that contribute to the development of a more sustainable, stable and serviceable financial and economic system.
 
The report's conclusions stress that 'the entities involved in the public consultation, showed that integrating ESG factors into both the organisations and the decision-making process, albeit dissimilar depending on the business model and the activity sector concerned, is a current and increasing concern' and furthermore 'across the different areas and activity sectors, highlight is given to the positive impact that integration of ESG factors may have for investors and society in general, reflecting greater confidence of the functioning of financial markets and institutions'. 
 
Among the main mentioned difficulties are the conceptual vagueness and confusion that is still visible in certain scopes of Sustainable Finance; the lack of market knowledge on the subject; the prevalence of management and investment models with an excessive short-term focus; difficulties faced in measuring ESG commitments, including the impacts and benefits for society and the investor; the heterogeneity of information reporting models; reporting costs, inter alia. 
 
In this document, the CMVM acknowledges 'the important role that regulators should play in this area within the scope of their mission, so as to ensure investor protection, namely, in terms of clarity, completeness, quality and comparability of information provided to the market, as well as, ensuring market stability and integrity by identifying, anticipating and mitigating risk and problems that must be considered as permanent supervision' and undertakes to consider the various challenges and concerns within its priorities and key activities for 2020, which will be made known by the beginning of the year.  
 
Henceforth, and meeting some of the concerns or requests included in these contributions, the CMVM is committed to working of four aspects:
  • promote the debate and information sharing on Sustainable Finance, by providing a specific area on its website with relevant and up-to-date information on Sustainable Finance;

  • keep permanent dialogue with market stakeholders to monitor concerns and difficulties encountered with a view to contributing to their clarification or to bring them to national and international discussions and solutions, particularly within the context of European regulatory changes concerning information and new benchmarks aligned with environmental impact indices;

  • clarify and monitor issuers' compliance of their sustainability duties including non-financial information reporting;

  • active and committed participation in international forums, i.e., IOSCO, ESMA and OECD and on the national front, the Sustainable Finance Reflection Working Group led by the Ministry of Environment, on the subject theme of Sustainable Finance.
The material initiatives on this subject are currently being assessed and will be disclosed together with the CMVM priorities for 2020. 
 

 
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