We welcome the targeted approach of the Commission in its review, recognising the overall success of the frameworks over the past decade.
The AIFMD framework,
in particular, has centred around the key role of the manager, in light
of the diversity of alternative investment funds. EFAMA advocates to
maintain the primary role of the manager in liquidity risk management
and to avoid the inclusion of product rules in a managers’ directive.
On the subject of delegation, we are seeking further clarity around the notification of delegation arrangements to ESMA, including the need for mandatory peer reviews.
In terms of depositary services,
we welcome the decisions of the European Commission not to introduce a
depositary passport and to extend the current depositary liability
regime to include ‘investor’ CSDs (Central Securities Depositories) in the custody chain.
Our full position is available here: Tweaking the AIFMD/UCITS Framework | EFAMA
EFAMA
© EFAMA - European Fund and Asset Management Association
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