Amendments to the Alternative Investment Fund Managers Directive (AIFMD) and to the Directive relating to undertakings for collective investment in transferable securities (UCITSD)

ECSDA Feedback to Commission on AIFMD Review In December 2021, the European Commission published a proposal to review AIMF, UCITS and ELTIF legislative acts as part of the Capital Markets Union (CMU) Package. The proposed amendment on the regulatory treatment of custodians of AIF and UCITS assets integrates an ESMA opinion from 2017 which carves out the Investor Central Securities Depository (CSD) from the…

Statement of principles INREV welcomes the opportunity to provide feedback on the European Commission’s (Commission) Proposal for a Directive of the European Parliament and of the Council amending Directives 2011/61/EU (‘AIFMD’) and 2009/65/EC (‘UCITS directive’) as regards delegation arrangements, liquidity risk management, supervisory reporting, provision of depositary and custody services and loan origination by…

Overall, Assogestioni welcomes the Commission’s proposal for the revision of the AIFM and UCITS Directives, except for some considerations with reference to the new proposals on the subject of a) delegation; b) loan originating funds; c) liquidity management tools; d) supervisory reporting; e) disclosure to professional investors. For more details, please see the Position Paper attached to this feedback.

In the EU, a total of €12.8 trillion is invested in investment funds by private and institutional investors. With assets of €3.4 trillion in UCITS and AIFs, Germany is the largest market with a share of 27 per-cent. In terms of funds launched in the EU, the German AIF market accounts for EUR 2,218 billion out of EUR 6,878 billion in the EU, which corresponds to a share of 32.2 percent.

Dear Sir/Madam, Please find the comments of IFM Investors Ltd on the Commission's proposals regarding a revised AIFMD and ELTIF regulation attached below. IFM would be delighted to discuss our suggested amendments further. If this would be of interest, please contact Dr [name removed] of Whitehouse Communications Ltd at [email removed] in the first instance.

The Alternative Investment Management Association (AIMA), the Alternative Credit Council (ACC) and the Bundesverband Alternative Investments eV welcome the opportunity to provide their members’ views on the European Commission’s (Commission) Proposal for a Directive of the European Parliament and of the Council amending Directives 2011/61/EU (the ‘AIFMD’) and 2009/65/EC (the ‘UCITS directive’) as regards delegation…

The German Insurance Association (GDV) is the association of insurers in Germany. Its more than 450 members represent over 95% of the insurance market in Germany with investments totaling 1,835 billion EUR (insurers, as of December 31, 2020), of which about one-third is invested in AIFs.

Dear Commission, In responding to the invitation contained in the consultation document on the Proposal for a Directive of the European Parliament and of the Council amending Directives 2011/61/EU and 2009/65/EC as regards delegation arrangements, liquidity risk management, supervisory reporting, provision of depositary and custody services and loan origination by alternative investment funds, ANASF – Associazione…

DUFAS (Dutch Fund and Asset Management Association) welcomes the European Commission’s (EC) review of the Alternative Investment Fund Management Directive (AIFMD) and its aim to set out targeted improvements to key provisions in the current framework.

Active Owners Denmarks feedback to European Commission proposal for targeted amendments to the Directives on Alternative Investment Fund Managers (AIFM) and Undertakings for Collective Investment in Transferable Securities (UCITS).

NMW recommends the European Commission and the European Parliament to consider ESMA’s views regarding the key concepts and definitions used by the AIFMD as the European Commission’s proposal did not reflect those views although they were highly relevant.

The Norwegian Securities Dealers Association is a national trade organisation for investment firms. We welcome the opportunity to provide feedback on the legislative proposal concerning the review of the Alternative Investment Fund Managers Directive (AIFMD), and we have the following remarks: The proposed art.

EFAMA welcomes the European Commission’s review of the Alternative Investment Fund Management Directive (AIFMD), setting out targeted improvements to key provisions in the current framework. Such targeted improvements will make strides in advancing the Capital Markets Union while maintaining the framework which has underpinned a decade of growth in the European Alternative Investment Fund (AIF) market and proven…

France Invest welcomes the Commission’s proposal for a review of the Alternative Investment Fund Directive (AIFMD). From a general standpoint, we fully support the approach adopted by the Commission to perform a targeted review of the Directive. Indeed, we acknowledge that the AIFMD contributed to improving financial stability, increasing investor confidence and enhancing the competitiveness of the EU industry.

FAIR, representing its 120 members consisting of banks, asset managers, NGOs, schools, social enterprises and committed individuals, would like to thank the Commission for the opportunity to provide feedback on the review at hand.

(1) The Commission’s Proposal to amend AIFMD aims to regulate i.a. loan-originating AIFs. In particular, art. 16(2a) of the Proposal requires that the AIFM shall ensure that the AIF it manages is closed-ended if the notional value of its originated loans exceeds 60 % of its net asset value.

The proposal regarding paragraph 5 of Article 61 of the Directive 2011/61/EU contains an explicit derogation from the obligation in this regard provided for by Article 21 of the same Directive, but it has a generic wording and, as such, it allows for a broad application.

We thank the European Commission for the opportunity to provide feedback on the legislative proposal concerning the review of the Alternative Investment Fund Managers Directive (AIFMD). ALFI welcomes the targeted nature of the review.

This pack will exclude retail investors and unlisted investees from the impact investing market, when those meet in retail-funds that invest in (smaller) private or microfinance loans that are not provided by banks. I’m also concerned that the proposal increases the risk faced by citizens investing in AIFs and limits the choice of impact investing products that banks can offer to their retail clients.

We thank the European Commission for the opportunity to provide feedback on the inception impact assessment concerning the review of the Alternative Investment Fund Managers Directive (AIFMD). According to this impact assessment, the major focus of the review should be on the directive’s effectiveness and the aim of completing a single market for AIFs in the context of the Capital Markets Union (CMU).

EFAMA, the voice of the European investment management industry, represents 28 Member Associations, 60 Corporate Members and 24 Associate Members. At end Q2 2020, total net assets of European investment funds reached EUR 17.1 trillion. These assets were managed by more than 34,200 UCITS (Undertakings for Collective Investments in Transferable Securities) and 29,100 AIFs (Alternative Investment Funds).

EFAMA’s RESPONSE TO EC ROADMAP ON THE AIFMD REVIEW The AIFMD is one of the pillars of EU regulation for asset managers and investment funds, which have a crucial role to play in the development of the Capital Markets Union (CMU) and the post Covid-19 economic recovery in the EU. EFAMA's views are on the roadmap are outlined in the document attached.

The Alternative Investment Management Association Limited (AIMA) and the Alternative Credit Council (ACC) appreciate the opportunity to comment on the European Commission’s (Commission) inception impact assessment on the AIFMD review. Our members note that the AIFMD review happens in a particular context with important economic challenges ahead.

The „Bundesverband Alternative Investments e.V. (BAI)“, the asset class- and product-spanning representation of interest for Alternative Investments in Germany with more than 240 members, welcomes the opportunity to comment on this Inception Impact Assessment.

With assets of EUR 3,000 billion, Germany is the largest market in the EU (according to the ECB as of 30 June, 2020) with a market share of 27 percent. In a context of continued inflows and growth of the asset management sector, financial stability bodies such as the European Systemic Risk Board (ESRB) and the European Central Bank (ECB) have called for an impact assessment of the resilience of the current framework…

France Invest acknowledges that the AIFMD contributed to improving financial stability, increasing investor confidence and enhancing the competitiveness of the EU industry. It however demanded a considerable adaptation effort from many market players, which have now integrated its impact.