The final response is in line with ALFI’s feedback on the Commission’s inception impact assessment, putting emphasis on the idea of a targeted review on the application and scope of the directive. Moreover, ALFI is of the view that the impact of the AIFMD on AIFs and AIFMs has been largely positive.
      
    
    
      
    
        
    
        View the ALFI  response.
The long version of the Commission’s questionnaire included 102 questions focussing on many different aspects:
- Functioning of the AIFMD regulatory framework, scope and authorisation requirements
 - Investor protection
 - International relations
 - Financial stability
 - Investing in private companies
 - Sustainability/ESG
 - Miscellaneous
 
The final response is in line with ALFI’s feedback on the 
Commission’s inception impact assessment, putting emphasis on the idea 
of a targeted review on the application and scope of the directive. 
Moreover, ALFI  is of the view that the impact of the AIFMD on AIFs and 
AIFMs has been largely positive. The association stated that the general
 concept of a manager directive should not be put into questions, e.g. 
by introducing product specific rules. There is primarily a need for 
stability to ensure the development of a brand and the European Union’s 
competitiveness. For various reasons, a merger of the UCITS  and AIFMD 
framework should not be made.
ALFI  will continue to follow the legislative process. An impact 
assessment may be published by the European Commission in the second 
quarter of 2021, and a legislative proposal is currently expected for Q4
 2021.
     
     
 
ALFI
      
      
      
      
        © ALFI - Association of the Luxembourg Fund Industry
     
      
      
      
      
      
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