FSA Outlines How to Make EU's AIFM Directive More Workable For Hedge Funds

Sally Dewar, Managing Director of the FSA'scurrent business models) the actual benefit of this
Wholesale Markets Division, gave a speech onregime is likely to be limited, particularly for the
September 17th, 2009 outlining four key areashedge fund industry." [emphasis added]
which need to be addressed in order to ensureI agree with Dewar, we all see value in "sensible
effective fund regulation and the regulatoryand proportionate harmonization of regulatory
approach which ought to be adopted.standards", but pan-European nor global regulatory
Speaking at the FSA's Asset Management Sectorharmony will be achieved by ignoring the
conference, Dewar said that "most of us can seegeo-political realities of global markets and players
value to the European and global capital markets,therein (Dewar's last point). Under current
and the wider economy, in sensible andproposals, many US banks will fail the
proportionate harmonization of regulatoryrequirements but the UK and US appear to be
standards in the areas under discussion."accelerating down the road of cross-border
The four areas Dewar highlighted are:regulation (see this article on the FSA and SEC
- Correct identification of the weaknesses in thedata share exchange agreement announced earlier
present regulatory arrangements and addressingthis week) while many banks are looking to the
them in a proportionate wayFar East as an alternative to London or New York
- Differentiation between types of alternativefor establishing their operations.
investment fund managementIt is hubris to suggest London is "the" European
- Adoption of a risk-based approach - the scopefinancial market but it is far more disturbing hubris
and thresholds of the Directive need to strike theon the part of AIFM proponents to believe raising
correct balance between imposing additional costsbarriers to entry for US players ( even when
and enabling regulators to identify and mitigatereferred to as "non-EEA") is not going to be
systemic risksviewed as anything but anti-competitive in New
- The need to take a global approach thatYork or Washington DC. More unsettling than that,
recognises the global nature of the sector andpractically every EU financial centre with hedge
does not impose unjustifiable geographicalfund operations is aware that money flows and if
restrictions on firms' business models that wouldthere are skilled personnel available in other world
significantly restrict investor choicefinancial centers, such as Hong Kong or Singapore
How serious the FSA are regarding AIFM can be(or New York or non-EU Switzerland), so will the
gauged by the fact that this year's Assetfund managers.
Management conference focused solely on AIFM.Perhaps the French and Germans will finally come
Also attending were Matts Odell (Swedish Financeto some understanding of how legislating without
Minister and Sweden currently holds the EUthe consent of the regulated is rule making for
Presidency) and Lord Myners who set out the UKthin air. Societe Generale experienced one effect
Government view.of French bonus restraint this week; several key
Sally Dewar's final point is the lynchpin aroundplayers left the company to set up a hedge fund
which "proportionate harmonization" will revolve;with US funding and will now determine their own
AIFM in its current form is a deeply divisive pieceremuneration. This underscores the US and UK
of legislation and as politically charged withapproach that remuneration, and especially
short-term motivation as can be. As Dewarbonuses, are effectively non-issues in the overall
stated, "But if there are restrictions on funds notscheme of global and domestic regulation.
domiciled in the EEA [sic US], then (based onSo much for bonus restraint President Sarkozy!