Comment Letter to ESMA on its Draft Technical Advice to the European Commission for Implementing AIFMD

September 13, 2011

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Topics: Advanced Method Advisers Act, AIF, AIFMD, Article 3(2), Article 61, Article 9(3), AUM, AUM Calculations, bespoke system, Box 1, Box 106, Box 13, Box 19, Box 2, Box 29, Box 78, Box 79, Box 81, Box 86, Box 88, Box 89, Box 93, Box 95, Box 99, CDS, CESR Guidelines, collateral, collateral directive, Commitment Method, Committee on European Securities Regulators, confidentiality, consultation paper, counterparties, counterparty exposures, credit default swap, depositaries, depositary, diligence requirement, Dodd-Frank, due diligence, ECB, EU investors, EU Passport, European Central Bank, European Commission, exposure, Financial Services Authority, foreign exchange hedging position, Form PF, FSA, G-20, gates, generally accepted accounting principles (GAAP), Gross Method, interest rate hedging position, international coordination, Investment Advisers Act of 1940, Level 2, Level 2 inputs, Level 3 inputs, leverage, liability regime, liability standards, liquidity risk, mark-to-market, market risk, marketing, MiFID, NAV, net asset value, omnibus accounts, operational risk, OTC transaction, passport regime, portfolio management, portfolio risk, prime brokers, private funds, professional indemnity insurance requirements, professional investors, proprietary information, re-hypothecation provisions, redemption policy, registration, remuneration, reporting period, repurchase agreement, retail investors, risk limits, risk management, safe-keeping function, SEC, securities lending agreement, segregation, semi-annual reporting, side pockets, sub-custodian, sub-investment managers, systemic risk, the directive, third party managers, transparency, U.S. Securities and Exchange Commission, UCITS Directive, underwriters, unobservable, valuation agents, Value at Risk, VaR,
From: MFA, Stuart Kaswell

To:

European Securities and Markets Authority, ESMA

MFA submitted comments to ESMA on its consultation on possible implementing measures of the Alternative Investment Fund Managers Directive (AIFMD). In our response, we encouraged ESMA to: (1) narrow the definition of assets under management to better focus the scope of the AIFMD on those managers and funds that should be of greatest regulatory focus for EU regulators; (2) provide greater flexibility in the methods by which managers calculate leverage; (3) ensure that the rules relating to depositaries do not unintentionally create concentration of risk or overly burdensome costs for fund managers; and (4) avoid imposing requirements on third country managers marketing under national private placement regimes that go beyond the requirements specified in the AIFMD.

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