SBAI Responds to ESMA CP Guidelines on Art 3-24

In the wake of the reversal of the SEC’s Private Fund Adviser Rules, the weight of transparency and fairness in alternative funds now lies on managers and investors.

The SBAI supports the latest efforts by the regulators to understand and address any potential risks emanating from non-bank financial institutions (NBFI) and welcomes findings which indicate resilience in the financial system despite prior concerns.

Over the last months, we have continued to engage and meet with the US SEC on a range of proposed rules – raising specific concerns about the unintended consequences of the Safeguarding Advisory Client Assets Rule and the Predictive Analytics Rule.