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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

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