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Those mainly relate to the overall calibration of the capital requirements, category thresholds and remuneration provisions for MiFID-licensed asset managers and to the importance of maintaining a level-playing field with asset managers subject to other regulations (UCITS and AIFMD).
Specifically, they commented on:
k-Factors double-counting: They have raised the fact that, under the Commission’s current proposals, MiFID-licensed asset managers would be subject to two (k-AUM and K-CMH) and possibly three (k-COH) k-factors, all applying to the same assets, which seems overly burdensome for an industry which bears almost no balance-sheet risks.
Remuneration requirements: They have reiterated the specificities of their industry and the fact that many risks linked to incentives and compensations are already mitigated by the inherent alignment of interests between fund managers and their investors/clients.
Class threshold: They commented on the fact that many of the thresholds determining whether a firm belongs to Class 2 or Class 3 are too low and do not properly reflect the risks associated to these firms
Transitional requirements: They noted that the Commission is due to publish a report on the impact of the new framework and they recommended that the transitional period shall extend until such time as the Commission, following the results of its report, determines that the transitional period is no longer needed.
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