AIFMD Review – ESMA’s Proposals on Delegation and Substance

According to a recent letter from ESMA to the European Commission (the “Letter”), practical experience has shown “many areas of the existing AIFMD framework that could be improved”. The Letter sets out ESMA’s key recommendations for improvements, which touch on a range of general issues in the legislative framework and key reporting issues. The Letter includes several recommendations regarding the rules applicable to delegation and substance, which are the focus of this briefing.

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