“The AIFMD covers a large and varied range of investment vehicles. There are close to 2,000 ‘alternative investment funds’ (AIF) in the UK alone.** IMA members are also the appointed investment managers of a very large number of AIF, domiciled in other jurisdictions.
“AIF investors are active market participants. Any further measures should not cut across their ability to access the investments and strategies they desire.
“The AIFMD is already a detailed piece of legislation. We therefore urge ESMA to resist introducing further unnecessary detail into Level 2 and 3 measures, and to use directives rather than regulations at this stage.***
“We support the principle of harmonisation, but detailed regulations could cause detriment to investors and run counter to the overarching principles articulated by the Commission.”
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