EFAMA has responded to CESR’s call for evidence on UCITS implementing measures. It highlights, among various recommendations:  

  • the need to make MiFID and UCITS Directive requirements on conflicts of interest and rules of conduct generally as well aligned as possible;  
  • that no measures should go beyond MiFID;  
  • that depositories should not have duties placed on them that might lead to different levels of protection for funds managed crossborder as opposed to domestically;  
  • that there cannot be a requirement to reassess risk management processes each time a new UCITS is authorised;  
  • that, on the KII, harmonisation must be of content and presentation and this must happen at Level 2; and  
  • several issues relating to master and feeder funds.