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Alternative Investment Fund Managers – review of EU rules

Banking and financial services

On the basis of the report on the application and the scope of the EU rules on alternative investment fund managers, the Commission will assess the changes necessary to improve the functioning of such rules. In doing so, EU legislation relating to Undertakings for the Collective Investment in Transferrable Securities, the European Venture Capital Funds and the European Social Entrepreneurship Funds may need to be adjusted.

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Public consultation

ID: 12648

Lobbying Activity

24 responses

Consultation response

BNP PARIBAS, 18 Mar 2022

Dear all, Please find attached the feedback of BNP Paribas Asset Management on the European Commission's text proposal on the AIFM Directive review. Kind regards, Laurence Caron Habib Head of Public Affairs BNP Paribas Asset Management

Consultation response

Gesamtverband der Deutschen Versicherungswirtschaft e.V., 23 Mar 2022

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. Therefore,…

Consultation response

Associazione Bancaria Italiana, 15 Feb 2022

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. This approach is in…

Consultation response

Investment Company Institute, 24 Mar 2022

Attached please find ICI Global's feedback on the Commission's AIFMD review proposal.

Consultation response

BVI Bundesverband Investment und Asset Management e.V., 24 Mar 2022

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…

Consultation response

BVI Bundesverband Investment und Asset Management e.V., 7 Jan 2021

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…

Consultation response

European Fund and Asset Management Association, 21 Mar 2022

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…

Consultation response

European Fund and Asset Management Association, 7 Jan 2021

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…

Consultation response

The Alternative Investment Management Association Limited, 7 Jan 2021

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…

Consultation response

Association Luxembourgeoise des Fonds d'Investissement, 9 Feb 2022

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. By this, the Commission recognises the general well-functioning…

Consultation response

Association Luxembourgeoise des Fonds d'Investissement, 7 Jan 2021

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…

Consultation response

Związek Banków Polskich, 24 Mar 2022

Please find enclosed the position of the Depository Banks Council within the Polish Bank Association.

Consultation response

Assogestioni - Italian Investment Management Association, 24 Mar 2022

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)…

Consultation response

FRANCE INVEST, 17 Mar 2022

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…

Consultation response

FRANCE INVEST, 7 Jan 2021

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.…

Consultation response

Dutch Fund and Asset Management Association, 23 Mar 2022

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. DUFAS however, wishes to emphasize that…

Consultation response

Regulatory Communication, 25 Jan 2022

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…

Consultation response

Bundesverband Alternative Investments e.V., 7 Jan 2021

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. As the EU Commission itself does, BAI…

Consultation response

European Association for Investors in Non-Listed Real Estate Vehicles, 24 Mar 2022

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…

Consultation response

IFM Investors (UK) Ltd, 24 Mar 2022

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 Andrew Tarrant of…

Consultation response

European Central Securities Depositories Association, 24 Mar 2022

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…

Consultation response

ASSOCIAZIONE NAZIONALE CONSULENTI FINANZIARI, 23 Mar 2022

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,…

Consultation response

Active Owners Denmark, 23 Mar 2022

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). Active Owners Denmark welcomes the opportunity to share our views…

Consultation response

FAIR - FINANCER ACCOMPAGNER IMPACTER RASSEMBLER, 16 Mar 2022

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. However, as an association working towards the development of…