Review of rules for alternative investment funds

Briefing 28-04-2022

The IA supports the proposal for the review of the AIFMD in an overall effective and transparent manner. It is based on solid internal and external expertise, including an array of technical recommendations from the relevant EU and international bodies in charge of monitoring and supervising investment funds. While the intervention logic of the mostly qualitative IA is clear, some aspects could have been substantiated in a more precise way. The highly technical analysis would have been more accessible to non-expert readers if interdependencies and links between the problems and drivers, and between objectives, options and monitoring indicators, had been indicated more clearly. The IA justifies limited quantification by a lack of data, providing quantified estimates (only) for the expected potential REFIT cost savings in the area of depositary services. The IA favours, for the time being, less prescriptive solutions in order to respect proportionality and subsidiarity. It highlights the need of additional targeted expertise for a number of questions, including as regards harmonisation of reporting requirements.