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10 May 2012
The Investment Management Association (IMA) has submitted its response to the HM Treasury on the implementation of Level 1 of AIFMD (Alternative Investment Fund Managers Directive), stating that small AIFMs targeting professional investors should be required to follow only the minimum requirements of the Directive.
Julie Patterson, IMA Director of Authorised Funds and Tax, said: “Given their size, it would not be feasible and cost effective for small AIFMs, which are marketing only to professionals, to comply with the full requirements of the AIFM Directive. The IMA therefore supports a proportionate approach which would require them simply to be registered by the FSA.
“However, for small AIFMs that target retail investors, we support maintaining the existing retail regimes for authorised non-UCITS retail funds and listed investment companies, for example investment trusts.” The IMA also said that this may be a good opportunity to re-assess whether regulation of charity funds should move from the Charities Commissions to the FSA, but that it was essential such funds retained their special tax status.
In addition the trade body highlighted that the sale of offshore funds domiciled in areas such as the Channel Islands, Jersey and Guernsey and sold to retail investors in the UK will need to be reviewed. These regions already have their own regimes, but the UK provisions for recognising such schemes will need to be reviewed when the AIFM Directive is implemented.
Read the full IMA response