Responding to the discussion paper, the Investment Management Association (IMA) said that the UK is a major domicile of Alternative Investment Funds (AIFs): the IMA estimates around two thousand AIFs in the UK alone, and a similar number sold from outside the EU into the UK. These fundsdeploy a wide range of investment strategies, investing across asset classes and regions.
The FSA discussion paper identifies a number of UK AIFs, including authorised non-UCITS retail schemes (NURS) and qualified investor schemes (QIS), charity funds, listed investment trusts, private equity and venture capital vehicles, and real estate funds and REITs. But a large number of unauthorised unit trusts are also likely to be within the scope of the AIFMD.
Commenting, Julie Patterson, Director at the IMA, said:
"We welcome this consultation paper. It helpfully summarises the many and diverse requirements within the Directive, and the extent of detailed requirements still to come from the Commission (Level 2) and ESMA (Level 3).
"Given the volume of amendments to the FSA Handbook which are necessary to implement these requirements, we recognise it is timely to reconsider the structure of the Collective Investment Scheme Sourcebook (COLL). And there are yet further EU rules proposed for smaller venture capital funds and ‘social entrepreneurship' funds which will need to be accommodated."
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