On April 15, the European Securities and Markets Authority issued a discussion paper on the implementation of Article 3 of the Alternative Investment Fund Managers Directive. The paper specifies ESMA's proposed approach regarding: (i) the calculation of assets under management to indentify funds under the authority of the Directive; (ii) the influence of leverage and cross-holding on such a determination; (iii) registration requirements; and (iv) procedures for smaller fund managers to "opt in" to the Directive. Comments must be submitted by May 16. ESMA Paper.