IMA has responded to ESMA's consultation on AIFMD Level 2 measures. It stresses the measures must recognise and cater for the diversity of funds the AIFMD covers. It notes the proposals sometimes go beyond what the AIFMD and other Directives require, and are sometimes overly prescriptive. It has significant concerns on the provisions relating to depositary liability, which it says have focused on limited circumstances in which there may be loss, rather than on the wider importance of proper due diligence. It also thinks the concept of "loss" is too tightly drawn, but cautions against any interpretation that would mean the depositary would have at all times to restitute assets held by a non-affiliated sub-custodian. IMA also stresses there must be an appropriate metric to measure leverage, and it does not agree with many of ESMA's comments. Finally, it thinks the proposed reporting requirements are too extensive. (Source: IMA responds on AIFMD Level 2)