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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