IMA's response to Treasury's consulting on implementing UCITS IV highlights:
- the need to discuss within ESMA any deviation from a pure copy-out approach to implementation;
- a request for more information on how FSA plans to meet certain requirements and when it plans to consult on key issues such as whether some parts of the AIFMD apply at umbrella or sub-fund level;
- urging FSA to make use of the transitional arrangements the AIFMD gives; a suggestion FSA should discuss with ESMA the possibility of harmonising the provision that allows UCITS to invest up to 10% of the fund in unapproved securities; and
- the need to clarify where responsibility for Anti-Money Laundering compliance lies.