EFAMA is pleased ESMA has tried to be consistent with other Directives when drafting its advice on AIFMD Level 2. However, it stresses ESMA should not go beyond its original mandate, and that there should be minimum regulation for non-UCITS funds aimed at professional investors. It also stresses the need for proportionality of approach. It says ESMA's work on defining different types of AIFs will be key in this respect. Like other respondents, EFAMA favours the option that would not require the depositary to act as central hub in cash flow. On the question of registration of investments, a number of EFAMA members do not think either option is fully appropriate, and also think the Level 1 Directive may need amendment. On collateral, EFAMA prefers the option that says instruments provided as collateral should not be held in custody if they are held under arrangements that satisfy the financial collateral Directive. It does not support any arrangements that would duplicate functions already taking place elsewhere. (Source: EFAMA responds on AIFMD Level 2)