ALFI response to ESMA consultation on marketing communications

12 Feb 2021 | Statements and Position Papers  

On 8 February 2021, ALFI responded to the ESMA consultation concerning guidelines on marketing communications under Regulation (EU) 2019/1156 of 20 June 2019 on facilitating cross-border distribution of collective investment undertakings.

View the ALFI response.

The Regulation specifies that AIFMs, EuVECA managers, EuSEF managers and UCITS management companies shall ensure that marketing communications addressed to investors are identifiable as such and describe the risks and rewards of purchasing units or shares of an AIF or units of a UCITS in an equally prominent manner, and that all information included in marketing communications is fair, clear and not misleading.       

Generally, the association underlined that marketing communications represent an opportunity for fund players to distinguish themselves and their products from their competitors. Therefore, ALFI’s members were of the view that imposing too strict format requirements for such type of documents, whether in paper or digital presentation, are not desirable. ALFI also stressed that the marketing and distribution of AIFs is very much different from the distribution of UCITS – in respect of marketing/distribution channels as well as in respect of target clients. As a result, one size guidelines could not fit all. For further details, please refer to the answers to the different questions raised by ESMA.