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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.