21 Aug 2020

This week, the European Securities and Markets Authority (ESMA) has published a letter to the European Commission proposing a number of changes as part of the upcoming review of the Alternative Investment Fund Managers Directive (AIFMD).

Specifically relevant to AREF Members is section 4 of the letter on delegation and substance and section 14 on external valuer liability. 

ESMA are calling for restrictions to the delegation of portfolio management functions to non-EU firms post-Brexit. You can read a summary of the main points on delegation covered in the ESMA letter in the IA Brexit Update linked below. The Investment Association (IA) are engaging closely with officials in both the UK and EU to ensure the global norm of delegation is protected. The IA are keen to hear direct from AREF members your initial reactions to the recommendations regarding delegation in the ESMA letter by emailing brexit@theia.org.

AREF has been lobbying on changes to external valuer liability within AIFMD. We are interested to hear your thoughts on ESMA’s recommendation on this. Please email these to info@aref.org.uk.



Jacqui Bungay

Jacqui Bungay

AREF Policy Secretariat , AREF

Jacqui provides policy guidance and secretariat services to the AREF Board and AREF Management Committee as well as the following AREF Committees: Corporate Governance, ESG & Impact Investing, Investor, Public Affairs, Research and Information and Retails Funds. In addition, Jacqui monitors members’ compliance with AREF’s Code of Practice. 

Jacqui joined AREF in 2014 after working for over 25 years in fund compliance, client relationships and administration at Natwest Trustee & Depositary Services.