BVCA has responded to ESMA's consultation on possible implementing measures for the AIFMD. It is worried the measures are not sufficiently tailored for private equity and also go beyond what the AIFMD envisages. One area of concern is on cash monitoring. It supports ESMA's option 2, which would not require the depositary to be the central hub, but even then it does not think it is necessary to monitor each individual cash flow related to the AIF. It also has significant concerns over the definition of financial instruments to be held in custody and is worried about the proposals related to safekeeping duties on "other assets" and believes some of ESMA's suggestions are unworkable in practice. It is concerned it may be difficult for some AIFMs to get professional indemnity insurance. (Source: BVCA Responds on AIFMD Level 2)