MFA has responded to FCA’s second consultation on implementing the AIFMD. It highlights:

  • the need for clarification on whether the transitional provisions apply equally to non-EU AIFMs;
  • broad agreement with FCA’s thinking on marketing but a need for clarification on certain important issues (for example, that marketing of an AIFM’s capabilities is distinct from the marketing of any specific AIF; and
  • the need for guidance on what would be a breach of the marketing prohibition that could lead to sanctions.

(Source: MFA Responds on AIFMD)