EFAMA has commented on the Commission’s proposals to amend the UCITS Directives in respect of depositories and remuneration. While it broadly supports the initiative to make the Alternative Investment Fund Manager's Directive (AIFMD) and UCITS requirements as consistent as possible, it has several concerns, not least the significant changes UCITS and their managers will have to make and the costs of this. It says many of the costs, including any costs related to the proposed inclusion of UCITS within the EU Investor Compensation Schemes Directive, will be passed on to customers. It says no change should be made without consideration of the particular position of UCITS. Finally, it says there is an urgent need to clarify in the UCITS Directive the counterparty limits for OTC derivatives in relation to central clearing. (Source:EFAMA Comments on UCITS V)