On 18 January 2011, ESMA published the responses to the December 2010 call for evidence by CESR on the Alternative Investment Fund Managers Directive (the “AIFM Directive”) implementing measures.

The responses (which are linked to ESMA’s website) include those from the following trade bodies:

  • the British Private Equity and Venture Capital Association (“BVCA”). The BVCA has responded in detailed to those questions relevant to the private equity and venture capital industry. It has also contributed to the response of the European Private Equity and Venture Capital Association (“ECVA”), although the full ECVA response has not yet been published by ESMA. Amongst other things, the BVCA response calls for the level 2 measures to be flexible enough to recognise the different asset classes and types of investment and investment strategy (for example, that the risks faced by a typical private equity or venture capital fund are very different to those faced by a hedge fund);  
  • the Investment Management Association; and  
  • the European Insurance and Reinsurance Federation.  

(The deadline for responses to the call for evidence was 14 January 2011).