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23 January 2015

PEGCC files regulatory comment letter


The letter submitted to ESMA responded to a “call for evidence” on the Alternative Investment Fund Managers Directive passport and whether it should be extended to third country AIFM.

The key point in the PEGCC letter is that the AIFMD passport regime should be extended to US AIFMs and the funds (both US and non-US) they manage. The letter reviews the fact that there are no significant obstacles regarding investor protection, market disruption, competition and the monitoring of systemic risk that would impede the application of the passport regime to US AIFMs and their funds.

According to PEGCC, extending the Passporting Regime to US AIFMs will mean that professional investors in the EU will continue to have access to AIFs managed by US AIFMs.  European investors should be permitted, within an appropriate regulatory framework, full flexibility in choosing between investing with European AIFMs and US AIFMs.

“Investment with US AIFMs serves a number of important functions for many European investors, including diversification of investment opportunities and access to attractive returns,” the letter reads. ”The PEGCC believes that not extending the Passporting Regime to US AIFMs would raise significant and important market access issues for US AIFMs and could seriously harm the interests of European institutional investors.  Extension of the Passporting Regime to US AIFMs is important for ensuring that European AIFMs and US AIFMs have a “level playing field” in connection with the marketing of AIFs to European professional investors.”

Full letter

Full press release



© PEGCC - Private Equity Growth Capital Council


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