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Safekeeping duties of depositaries for Alternative Investment Funds

Banking and financial services

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Public consultation

ID: 1778

Lobbying Activity

13 responses

Consultation response

Association for Financial Markets in Europe, 26 Jun 2018

Please see our feedback in the attached file. AFME Contact: Gary Simmons

Consultation response

Intesa Sanpaolo, 25 Jun 2018

With reference to the consultation, Intesa Sanpaolo SpA acts as an delegated sub custodian for a number of depositaries acting on behalf of AIF and UCIT clients. We welcome the opportunity to comment on the draft legislation as it will allow for clarity in particular for the parts which may impact…

Consultation response

Deutsche Börse AG, 25 Jun 2018

Introductory remarks The feedback provided in this document conveys the views and opinions of the Deutsche Börse Group’s post-trade arm Clearstream Banking Luxembourg S.A., Clearstream Banking Frankfurt AG, and LuxCSD S.A. (jointly referred hereafter as “Clearstream”). Clearstream is a duly…

Consultation response

AMUNDI AM, 25 Jun 2018

In order to better protect investors’ interests, Amundi advocates for a more granular segregation of assets than proposed by the European Commission (EC). We also recommend that the legal opinion required when third country based custodians receive a delegation from the depositary of a fund…

Consultation response

European Fund and Asset Management Association, 26 Jun 2018

Please kindly refer to the uploaded document.

Consultation response

European Savings and Retail Banking Group, 26 Jun 2018

ESBG would like to submit the following comments regarding the draft Commission Delegated Regulation amending Delegated Regulation (EU) No 2016/438 and the draft Commission Delegated Regulation amending Delegated Regulation (EU) No 231/2013, as regards safe-keeping duties of…

Consultation response

Association Luxembourgeoise des Fonds d'Investissement, 26 Jun 2018

The Luxembourg depositary banking sector, represented for the purposes of this feedback by ALFI and ABBL, welcomes the European Commission’s initiative to follow up on the ESMA opinion and is happy to provide feedback as per the attached document in regard of the different proposals made. We…

Consultation response

The Bank of New York Mellon, 22 Jun 2018

BNY Mellon welcomed the publication of the ESMA Opinion on Asset Segregation in July 2017. We also welcome the European Commission’s publication of draft delegated regulations in respect of the safe-keeping duties of depositaries (following on from this ESMA Opinion). BNY Mellon thanks the…

Consultation response

Irish Funds Industry Association CLG, 26 Jun 2018

Irish Funds welcomes the opportunity to provide its feedback on the proposed amending Delegated Regulations (EU) No 231/2013 regarding safekeeping duties of Depositaries (“the Draft Regulations”). Irish Funds acknowledges that the Draft Regulations are seeking to provide further clarity with…

Consultation response

UK Finance, 25 Jun 2018

UK Finance is pleased to respond to the European Commission Delegated Regulation amending Delegated Regulation (EU) No 231/2013 as regards safe-keeping duties of depositaries. UK has three key recommendations for the European Commission, which are as follows: (i) The depositary should not be…

Consultation response

The UK Depositary Association, 26 Jun 2018

The Depositary and Trustee Association (“DATA”) represents UK depositaries of Alternative Investment Funds (“AIFs”). DATA therefore welcomes the opportunity to respond to the European Commission’s consultation on proposed changes to the EU regulation relating to safekeeping duties for depositaries…

Consultation response

Association of Global Custodians, 26 Jun 2018

The European Focus Committee of the Association of Global Custodians (“AGC-EFC”) is grateful for the opportunity to share its views on the European Commission's draft Delegated Regulations (collectively, the “Draft Amendments”) each amending the current EU 2013/231 (“AIFMR”) and EU 2016/438…

Consultation response

Association Française des Professionnels des Titres, 25 Jun 2018

We understand that this proposal of amending delegated regulation only takes into account the point relating to the assets segregation of the ESMA’s opinion of 20 July 2017 on Asset segregation and application of depositary delegation rules to CSDs, and that the point of the ESMA’s opinion relating…