MFA strongly supports the FCA’s proposed removal of the business restriction that has given rise to unnecessary complexity and costs for firms, restricting businesses from carrying out the full range of regulated activities they require.
MFA:
- Agrees that the structural conflicts of interest issues that the business restriction was originally intended to mitigate can be more appropriately and proportionately addressed via other means.
- Supports the FCA’s indication that it would likely exclude all AIFMs from transaction reporting in connection with pursuing option 4.
- Does not think it is appropriate for the FCA to apply subjective value judgments on why a particular firm might wish to be authorised as an AIFM versus, for example, a MiFID investment firm.