CP12/32: Implementation of the Alternative ... - BVCA admin
CP12/32: Implementation of the Alternative ... - BVCA admin
CP12/32: Implementation of the Alternative ... - BVCA admin
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<strong>CP12</strong>/<strong>32</strong><br />
<strong>Implementation</strong> <strong>of</strong> <strong>the</strong> <strong>Alternative</strong> Investment Fund Managers Directive<br />
innovation by firms. However, we believe that <strong>the</strong> draft rules will allow for o<strong>the</strong>r types <strong>of</strong><br />
innovation within firms or <strong>the</strong>ir funds, such as allowing for new investment strategies.<br />
Promoting public awareness<br />
17. These proposals are not intended to promote public awareness.<br />
The international character <strong>of</strong> financial services and markets and<br />
<strong>the</strong> desirability <strong>of</strong> maintaining <strong>the</strong> competitive position <strong>of</strong> <strong>the</strong><br />
United Kingdom<br />
18. The harmonised AIFMD regime across Europe aims to develop a level playing field<br />
for asset managers operating across different Member States. It also seeks to achieve<br />
consistent regulatory approaches and supervisory practices, and improved frequency<br />
and quality <strong>of</strong> disclosure.<br />
19. Although AIFMD is mostly maximum harmonising, in <strong>the</strong> few areas where we have <strong>the</strong><br />
option to make a discretionary decision we have taken account <strong>of</strong> <strong>the</strong> competitive<br />
implications between firms based in <strong>the</strong> UK and in o<strong>the</strong>r countries. In developing our<br />
proposals we have considered <strong>the</strong> implementation efforts in o<strong>the</strong>r Member States.<br />
The need to minimise <strong>the</strong> adverse effects on competition<br />
Annex 4X<br />
20. As explained in <strong>the</strong> CBA, our proposals may have a material impact on competition for<br />
some asset managers. However, when writing rules we have attempted to calibrate <strong>the</strong>m to<br />
<strong>the</strong> risks to our objectives we have identified, bearing in mind <strong>the</strong> impacts on competition.<br />
Why our proposals are most appropriate for <strong>the</strong> purpose <strong>of</strong> meeting<br />
our statutory objectives<br />
21. Our proposals draw on engagement with those interested in <strong>the</strong> asset management sector.<br />
We have taken account <strong>of</strong> <strong>the</strong> feedback to DP12/1 in our fur<strong>the</strong>r policy development. We<br />
believe <strong>the</strong> proposals described in this CP represent <strong>the</strong> most appropriate and proportionate<br />
approach to implementing AIFMD.<br />
A4:4 Financial Services Authority November 2012