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.