ESMA has updated its Q&As on the application of the Alternative Investment Fund Managers Directive (AIFMD). A new Q&A is added to clarify the application of the AIFMD notification requirement to AIFMs managing umbrella AIFs on a cross-border basis:
Q5: An AIFM intends to manage an EU umbrella AIF on a cross-border basis by way of the AIF management passport (Article 33 of AIFMD). Does the AIFM have to identify all the compartments of the umbrella AIF in the notification? A5: Yes. In the notification, the AIFM has to identify the umbrella AIF, as well as the name and investment strategy of its compartments, to facilitate administrative procedure in home and host Member States. Any change in the composition of an umbrella AIF that is managed on a cross-border basis has to be notified to the competent authorities pursuant to Article 33(6) of AIFMD.