AIMA's response to ESMA's consultation on possible implementing measures for the AIFMD is broadly supportive of ESMA's proposals. It is pleased ESMA has recognised the diversity of entities that will fall under the AIFMD, and has allowed flexibility and proportionality. However, in some areas, even where the advice is based on other Directives, specifically MiFID and the UCITS Directives, AIMA thinks some changes are necessary and thinks the proposals sometimes go beyond what the Directives require. AIMA also strongly feels the measures should take the form of a Directive, saying it would be "nothing short of devastating" to put the provisions on depositaries in a Regulation. Despite broadly supporting the proposals, AIMA raises some serious concerns. It is concerned about the costs of implementing some of the proposals on depositary liability and about the effects of inappropriate measures of leverage. It wants to see greater consistency in transparency of regulatory reporting and is worried about the proposals on liquidity management. In particular, it is not happy with ESMA's proposals on "special arrangements" and their effects on liquidity. On specific areas of the consultation where ESMA provided options, AIMA supports the option for monitoring of cash flows that does not require an account to be opened at the depositary. (Source: AIMA Responds on AIFMD Level 2)