ALFI responds to the EBA/ESMA discussion paper on IFD/IFR

On 3 September, ALFI responded to the EBA/ESMA discussion paper on the potential review of the investment firms’ prudential framework. In its response, ALFI highlights that there is no need to impose additional capital requirements for UCITS management companies and AIFMs providing MiFID ancillary services, nor to restrict the amount of such service, as the UCITS and AIFM Directives have already been very recently reviewed and already contain a specific regime for management companies and AIFMs. ALFI suggests that, should any alignment of the capital requirements rules be opted for, duplication of requirements be avoided and proportionality be respected.

Moreover, ALFI also questions the merit of aligning the remuneration requirements for investment firms and UCITS management companies and AIFMs, as the asset management and the credit institution model are not comparable and the risks involved are different.

View the ALFI response.