At the same time, however, as we have seen, a large percentage of those same AIFMs continue to put off their gap analyses, impact assessments and implementation plans related to the Directive.
The math simply does not add up.
The AIFMD is one of the most wide-reaching, ambitious and complex regulatory regimes ever introduced into the alternative investment management industry. The tempo is accelerating. The European Commission is close to finally adopting the level 2 implementing measures. Firms will be forced to implement significant changes to their capital, clients, business operations and regulatory compliance and reporting very quickly, with a hard deadline looming on the horizon. The stakes are high on several key fronts, including risk mitigation, competition and profitability.
Nonetheless, a significant percentage of industry players continue to wait to see the final implementing measures before beginning their preparations in earnest. Unfortunately, those firms that wait to prepare risk exposing themselves to a raft of potential problems, including being forced to contend with compressed timelines, paying higher costs for retaining external expertise, the strain related to over-stretching in-house resources, the expected difficulties associated with securing the services of a preferred depositary and so on. In addition, of course, non-compliance as of the July 22, 2013 implementation deadline will preclude AIFMs from raising new capital until they are compliant with the Directive.
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