EFAMA has also responded on the UCITS depository function and UCITS managers’ remuneration. It criticises the short consultation period, and says longer consultation on the combined intertwined package of this, the AIFMD implementing measures, the PRIPs initiative, the MiFID Review and the Insurance Mediation Directive Review would have been preferable and arguably necessary. On the subject of the consultation it is committed to supporting measures to improve the existing UCITS depository regime but notes risks to investors cannot be completely avoided so regulators should not try to regulate the risk away. It also underlines the importance of consistency between the UCITS and AIFMD approaches and the need to take into account other initiatives such as the proposal for a Securities Law Directive. Finally, it says UCITS investors will receive such good protection that UCITS need not be included in the Investor Compensation Schemes Directive. On remuneration, it notes the differences between the role of UCITS managers and the roles of those to whom remuneration rules apply in the banking or investment banking industry. That said, it sees places where UCITS laws could be more consistent with both the AIFMD and the third Capital Requirements Directive. It also comments that many of its members may be covered by differing requirements for different types of business and that there should be no conflicting standards or disproportionate compliance burdens for them to tackle. (Source: EFAMA reply to European Commission consultation paper on the UCITS Depositary function and on the UCITS Managers’ Remuneration)