ALFI’s response to the European Commission’s Public Consultation on Derivatives and Market Infrastructures

8 July 2010 | Statements and Position Papers  


ALFI appreciates the opportunity to respond to the European Commission’s Public Consultation on Derivatives and Market Infrastructures.

The following feedback only focuses on legal specialties of fonds commun de placements (FCPs). For the avoidance of doubt, there are also legal specialties regarding société d´investissement à capital variable or à capital fixe (SICAV / SICAF) respectively umbrella structures (Sub funds), which should be considered in the in tended regulation of derivatives and market infrastructures. We believe that already our feedback regarding FCPs discloses that investment funds regardless of their
particular legal structure include legal specialties which would result in gaps in the intended regulation or the breach of national law if not being considered. Read more.