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EFAMA Response to EC Roadmap on review of EU AIFM

06 January 2021 | Policy position
EFAMA Response to EC Roadmap on review of EU AIFM

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.

The Commission’s Report to Council and Parliament assessing the application and the scope of Directive 2011/61/EU on alternative investment fund managers provides a balanced analysis leading to the conclusion that, overall, the AIFMD regime is working well. We welcome the recognition that the framework has improved the monitoring of risks for the financial system and the cross-border raising of capital for investments in alternative assets. We also agree on the assessment of the important role played by the AIFMD in creating an internal market for AIFs and reinforcing the regulatory and supervisory framework for AIFMs in the Union. AIFMs are now operating with greater transparency for investors and supervisors, helping building confidence in financial markets.


When identifying possible areas of action, the Report is weighted and prudent, acknowledging the need for a holistic approach and the importance of assessing the impact of potential amendments to the directive and its implementing acts.


Against this solid analysis, also underpinned by the conclusions of the report mandated to KPMG, and in the absence of evidence of market failures, it is our strong belief that the upcoming AIFMD review should only introduce targeted changes either at Level 2 or Level 3 when necessary and duly justified by factual evidence of shortcomings. It is important to bear in mind that any change to the current framework might create more uncertainties, generating more operational costs to apply those changes.


EFAMA looks forward to further contributing to the AIFMD review notably by providing a detailed and evidence-based response to the European Commission’s consultation running until the end of this month. We have set out below our high-level views on the key sections of the European Commission’s consultation document on AIFMD.

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