While largely welcoming the Commission's proposals, in particular as they pertain to increased availability of liquidity management tools for fund managers, the ESRB has suggested amendments.
      
    
    
      The European Systemic Risk Board (ESRB) has published a letter
 sent to members of the European Parliament on the subject of the  
European Commission’s proposed amendments to the Directive on 
Alternative Investment Fund Managers (AIFMD) and the Directive on the 
coordination of laws, regulations and administrative provisions relating
 to undertakings for collective investment in transferable securities 
(UCITS).
While
 largely welcoming the Commission's proposals, in particular as they 
pertain to increased availability of liquidity management tools for fund
 managers, the ESRB has suggested the following amendments:
1. Addressing liquidity mismatches in open-ended AIFs:
 ESRB proposes that ESMA  be given the power to draw up a list of 
inherently less liquid assets.  Managers of open-ended AIFs investing in
 such assets are to be required to demonstrate that they can follow 
their investment strategy in all foreseeable market conditions.
2. Access to data for monitoring systemic risk: 
 ESRB proposes establishing datasharing arrangements, as well as 
high-frequency reporting in crisis situations, for the benefit of all 
authorities with macroprudential mandates (including the ESRB).
3. More guidance on the use of macroprudential leverage limits: ESRB calls for further clarification regarding the operationalisation of leverage limits.
AIMA
      
      
      
      
        © AIMA - Alternative Investment Management Association 
     
      
      
      
      
      
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