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09 January 2015

ALFI response to ESMA call for evidence AIFMD passport and third country AIFMs


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ALFI is of the view that an extension of the passport to non-EU managers in 2015 would be premature.


ALFI thinks that autumn 2015 is not a realistic date for an extension of the AIFMD passport to third countries. ALFI thinks a decision by the European Commission on an extension of the passport should be deferred by at least three years until 2018, i.e. the point in time where National Private Placement Regimes are meant to disappear.

A possible decision in favour of an extension at that stage should be followed by a transition period of one year for the abolishment of National Private Placement Regimes the benefit of existing AIFs and their managers, which will have to get familiar with the requirements set by the AIFMD.

The responsiveness of national regulators and the way of how they can be contacted differ. Moreover, the information on the process was fragmented from one regulator to the other. Still, ALFI has the impression that the overall experience of using the AIFMD passport in Luxembourg and the UK is positive. The regulator-to-regulator notification process for marketing funds in another EU Member State (or EEA country) works well. From a Luxembourg perspective, the creation of guidelines/circulars – at a home and host country level – providing detailed information on article 32 AIFMD registrations would result in the creation of a more harmonised passporting framework and would also help the promoters to better tailor their internal processes and documentations.

Full ALFI response



© ALFI - Association of the Luxembourg Fund Industry


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