AIMA, together with the Managed Funds Association (MFA), published a position paper where it welcomes the European Commission’s omnibus regulation and omnibus directive proposals aiming at facilitating investment funds cross-border distribution.

AIMA is supportive of the overall objectives of the proposals although we are suggesting some amendments to further develop EU’s capital market union : (i) the pre-marketing definition should be broadened in order to allow AIFMs  to test investors’ interests regarding established AIFs and in order to be coherent with the current definition of “marketing” under AIFMD; (ii) references to investors thresholds in the process of de-notification is not relevant and should be deleted due to the complexity of identifying end investors; (iii) ESMA’s central database of information should be constantly up-to-date and (iv) the physical ban on local entities should be extended to all third party entities (such as third party agents).

This file is now discussed at the level of the Council of Member States in Brussels and we will be closely monitoring and engaging with policy makers.

For any questions, please contact Marie-Adelaïde de Nicolay.