Alternative Investment Fund Managers Directive (AIFMD) - Meeting the challenge | Brochure
As of July 2013, the new regulatory landscape for AIFMs will be in place
The Alternative Investment Fund Managers Directive (AIFMD) is no longer a distant set of requirements subject to ongoing negotiation. The European Commission’s detailed ‘Level 2 Regulation’ has settled the rules for compliance with this new, game-changing regulatory regime.
For the first time, a vast and diverse range of fund managers will be required to operate under a new and comprehensive EU regulatory framework with far reaching business impacts.
AIFMD is far more than a compliance exercise – it will alter the competitive landscape in a changing and uncertain marketplace. It will impact not just the AIFM but almost every actor across the fund management value chain. Compliance must be approached from a strategic perspective given the range of impacts and costs involved.
The time to act is now
AIFMD must be implemented nationally by 22 July 2013. The Level 2 Regulation was originally expected in the first quarter of 2012 but ongoing negotiations delayed its release until December 2012. This has made the timeframe for compliance even tighter. AIFMs need to be ready to submit their application for authorisation by 22 July 2014.
How we can help
Deloitte combines expertise in assurance/risk, regulatory, taxation, operational and strategic consulting to deliver an integrated AIFMD solution for your business. We provide global resources and capabilities, yet our presence is local – with a clear understanding of your market and your way of doing business.
Our AIFMD solutions framework
|Strategic assessment||The strategic assessment considers cost, existing business model infrastructure and licences as well as geographical impact (tax, regulatory) to identify your challenges and opportunities. This assessment will demonstrate how to best align your current business objectives with the AIFMD framework or, as the case may be, to remain out of scope.|
|Compliance project management||The gap analysis highlights areas requiring action to achieve AIFMD compliance, to produce a compliance plan indicating the action owner. Where the compliance function has limited resources, action points such as drafting of specific policies and procedures, calculation of capital/professional indemnity cover and due diligence, can be outsourced to Deloitte.|
|Risk and valuations governance||Deloitte provides assistance in the set up and review of an AIFMD compliant risk manager by advising on leverage calculation, liquidity management and the valuation model, as well as providing risk stress testing and back testing. Our solution also covers a review and implementation of new controls, procedures and reporting.|
|Independent valuation advice||Deloitte provide assistance in designing and reviewing valuation models. Our experts also propose independent valuation services depending on applicable local regulations.|
|Remuneration compliance||Our experts will guide you through the AIFMD requirements relating to remuneration, analysing the impact this will have on your current remuneration framework and advise on new policies and procedures required. This advice also covers personal taxation aspects and human resources consulting and guidance, offering a pragmatic approach to AIFMD’s remuneration requirements.|
|Operational realignment||By reviewing the readiness of your operating model, we assess the need for operational realignment and provide an optimal target operating model taking into account the delegation model and the existing functions.|
|Reporting||Our solution to the increased reporting requirements consists of conducting a gap analysis based on the requirements compared to existing reporting processes and how these can be adapted and enhanced, as well as advice on the areas of the control framework that can be outsourced.|
|Distribution||Deloitte offers a distribution hub to assist you to benefit from the cross border distribution passport. We provide the market intelligence to assist those without a passport to understand the national private placement regimes of the EU member states, as well as worldwide.|
|Audit attest||Deloitte’s auditors can assess your entity under the ISAE 3402 on the investment management function, the ISAE 3000 on the risk management process and the ISRS 4400 agreed upon procedures on delegated functions.|
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