Published: 25th October 2018

ESMA has added a new Q&A clarifying the application of the Alternative Investment Fund Managers Directive (“AIFMD”) notification requirements with regard to AIFMs managing umbrella Alternative Investment Funds (“AIFs”) on a cross border basis.

In the updated Q&A document, ESMA has confirmed that an AIFM that intends to manage an EU umbrella AIF on a cross-border basis by way of the AIF management passport must, in the notification, identify the umbrella AIF as well as the name and investment strategy of all its compartments to facilitate administrative procedures in the home and the host states.

Additionally, any change in the composition of the umbrella AIF that is managed on a cross-border basis has to be notified to the compartment authorities pursuant to Article 33(6) of AIFMD.

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