ESMA recently published their recommendations regarding the
review of the Alternative Fund Managers Directive AIFMD. The full
letter can be read
here.
Within the letter ESMA suggests that more specific requirements
on white-label service providers would be advisable specifically as
some member states raised doubts as to whether those business
models would be in line with the AIFMD and UCITS.
White Label Service Provider are necessary for diversification
within the European Fund Industry
In our opinion White-Label providers play an important role in
the European Fund Landscape. Specifically smaller asset managers
cannot afford setting up the whole infrastructure for a fund
management company and their access to the market of launching
investment vehicles relies on White-Label service providers. So
when it comes to the question whether these business models shall
be permissible on the European Market my answer is a 100% YES.