On occasion of this most recent consultative work on the SFDR topic, EUSIPA reiterated again the sectoral view that structured investment products should be brought into scope of the SFDR, so as to appreciate their sustainability enhancing effect which is at least similar to that of other asset classes, as mainstream UCITS funds. Beyond this purpose, their inclusion would also serve the purpose to eradicate a major cause for legal uncertainty at the point-of-sale emanating from MIFID currently covering structured products with ESG features in the target market rules, while SFDR does not.
The full EUSIPA statement can be found under below link.