MFA welcomes the FCA’s extensive efforts in reviewing the UK AIFM regime with a view to achieving greater proportionality, simplicity and international alignment.
MFA suggests:
- Limiting the size calculation to the NAV of alternative investment funds (“AIFs”) managed by the firm and not residual Collective Investment Schemes (“CIS”).
- Clarification of any substantive expansion of the AIF perimeter, which would have consequences beyond those considered in the Consultation Paper.
- Further simplification of investor disclosure and reporting rules regarding professional investors, particularly in the case of third country AIFMs, and to give AIFMs more flexibility to meet the FCA’s principles in the manner they consider best suited to their business and group arrangements.
- Revisiting whether prudential requirements should apply at all for asset managers, particularly for those who deal only with professional investors.
