In October 2018, ESMA added a new question in its Q&A on the AIFM Directive.
In answer to the question on whether an AIFM that intends to
manage an EU umbrella AIF on a cross-border basis by way of the AIF
management passport (Article 33 of AIFMD) has the obligation to
identify all the compartments of the umbrella AIF in the
notification to its competent authority, ESMA replies positively
and confirms that the AIFM has to identify the name and investment
strategy of all the compartments of the AIF, in order to facilitate
the administrative procedure in home and host Member States.
ESMA also adds that any change in the composition of the
compartments of an umbrella AIF that is managed on a cross-border
basis has to be notified to the competent authorities pursuant to
Article 33(6) of AIFMD.
