On 7 April 2014, ALFI responded to the consultation “Assessment methodologies for identifying non-bank non-insurer global systemically important financial institutions” conducted by the International Organization of Securities Commissions (IOSCO) and the Financial Stability Board (FSB).
ALFI is of the view that highly regulated funds such as UCITS in Europe or regulated Alternative Investment Funds (AIFs) that already comply with detailed diversification rules and rules on leverage are not systemically important and do not cause systemic risk. In addition, asset managers are also not a source of systemic risk. They are not the counterparty to trades they conduct on behalf of their clients. Neither are they responsible for the allocation by clients of their assets. Managers act as agents for their clients. ALFI considers it more appropriate to focus on market activities that may give rise to such issues.
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