AIMA argues that the directive creates:

 

·         potentially major difficulties for non-EU funds and/or non-EU managers in accessing the EU market. Marketing of funds by managers will only be allowed with a special marketing passport that the directive creates. However, the directive also delays its introduction by three years and imposes significant obstacles (such as demonstrating regulatory and tax equivalence) to obtaining it.

·         difficulty and makes it costly for non-EU funds and managers to access an EU market that it is clearly protectionist in effect, if not in intent.

·         a very significant impact on investors. EU investors, in particular, face a situation where they can use only EU asset managers of EU domiciled funds investing assets under an EU custodian. And international investors with EU funds or managers will find that their costs will go up and their returns will go down because of the restrictions and compliance costs the directive imposes.

 

AIMA believes that the provisions of the draft directive with protectionist consequences will not only hit the industry worldwide but also weaken the competitiveness of the EU in investment management and make the EU a less attractive destination for international investment.  “Naturally, we hope that it can be revised to avoid this.”