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ALFI notes that EuSEF/EuVECA forms have not been very popular in the market so far, partly because of the very restrictive definitions of their investment universes. While recognising that these forms are meant to remain “niche” products, ALFI urges ESMA and the Commission not to add to the complexity at Level 2. This approach is in line with the Commission’s request to ESMA’s advice to avoid being excessively burdensome. ALFI notably believes that more flexibility should be left to market players and national authorities regarding social impact measurement rules.
ALFI welcomes ESMA’s suggestion for core functions of the managers to be to manage the fund, not to provide support services to portfolio companies. Investors in funds do not typically expect explanation as to why managers would not provide services to portfolio companies.
To provide market players with a template detailing the necessary information towards investors would surely contribute making EuSEF more attractive for both investors (for comparison purposes) and managers (ALFI believes that it would be less costly for most of them to apply a single common simple template rather than to develop their own ones).