MFA submitted a letter to the European Commision on the functioning of the Alternative Investment Fund Managers Directive (AIFMD), calling for a more proportionate and risk-based regulatory framework for alternative investment fund managers (AIFMs).
A summary of MFA’s comments is as follows:
- AIFM asset size alone is an insufficient proxy to assess whether regulatory relief is appropriate.
- MFA recommends a more risk-based and outcomes-focused approach.
- MFA further recommends reconsideration of the leverage measurement under Annex IV.
- MFA recommends that the Commission reconsider the duplicative, inefficient dual-sided reporting regimes.
- MFA urges the Commission to preserve longstanding global market access through delegation and National Private Placement Regimes (“NPRRs”).
