ALFI response to ESMA call for evidence AIFMD passport and third country AIFMs

To access the ALFI response here.

Download the document here.

ALFI is of the view that an extension of the passport to non-EU managers in 2015 would be premature. Moreover, ALFI thinks that abolishing national private placement regimes (NPPRs) is a prerequisite for an extension of the passport to third countries. A parallel system would cause market distortion by putting EU AIFMs at a clear disadvantage. Therefore, ALFI concludes that a decision by the Commission should be deferred until at least 2018, i.e. the point in time where NPPRs are meant to disappear. A possible decision in favour of an extension at that point in time should be followed by a one year transition period.