ALFI understands and appreciates ESMA’s intention to achieve alignment between UCITS and AIF documentation, because this usually facilitates both filings and checks by regulators.
ALFI responded
to the ESMA consultation on draft technical standards on the
notifications for cross-border marketing and management of AIFs and
UCITS
The aim of the consultation was to develop proposals on implementing
technical and regulatory technical standards to specify the information
to be provided, as well as the content and format of notification
letters to be submitted by UCITS, management companies and AIFMs to the
national competent authorities to undertake cross-border marketing or
cross-border management activities in host Member States, as well as the
procedure for the communication of the notification file by the
relevant home NCA to the host NCAs of the Member States where these
activities are envisaged.
ALFI understands and appreciates ESMA’s intention to achieve
alignment between UCITS and AIF documentation, because this usually
facilitates both filings and checks by regulators. However, it is
important to note that certain points are only relevant to either UCITS
or AIFs. ALFI notes that in particular for UCITS more detailed
information (such as the description of a marketing strategy) would be
requested. The draft response questions the relevance of those aspects
for each notification of a sub-fund and insists that only information
that is really needed for the supervision of a fund or manager by NCAs
should be collected.
View the ALFI response.
ALFI
© ALFI - Association of the Luxembourg Fund Industry
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