In a statement released on Friday 16 March 2018, Alfi saluted the intentions of the European Commission in its efforts to remove barriers to cross-border fund distribution while ensuring a high level of investor protection, yet took the view that:

“The proposal could have been given greater scope and effectiveness, in particular with regards to the notions of marketing and pre-marketing which have not been extended beyond the AIFM Directive context.”

Alfi said it supports an approach where the European Securities and Markets Authority would provide guidelines and examples to ensure a common understanding and implementation in the EU.

The trade group also considered that the text as proposed does not provide for the level of harmonisation required to effectively achieve the removal of barriers to cross-border distribution of investment funds in the EU.

“The framework outlined for pre-marketing, the conditions set for the de-registration of investment funds and the requirements for local administrative agents remain too restrictive in the context of actual practice,” the Alfi statement noted.