Reform Asset Management License - (Niche Problem)

1) Getting an Asset Management License in Europe is a nightmare. In some countries, it is almost impossible (Italy), while in others, it is still very expensive and time-consuming (E.g., France).
It harms innovation and competitiveness to the point that, on average, EU investors have access to more expensive, less performant financial products than US investors.

How?
2) Create some decently flexible conditions for emerging PMs/Asset Managers. In US there are pretty flexible constraints when managing AUM < 100ml for ‘Family & Friends’. In the EU, in theory, you need a license from day 1 (expected yearly license cost: >100k, very often in the 200-300k ballpark).

3) Different compliance needs should be imposed depending on the level of involvement of the Asset Manager. The end goal of any License should be only to allow ‘capable and qualified’ people to manage other people’s money. Why? So they’ll preserve their capital.
What are the main risks?
a) Counterparty risk: you give money to a VC/PE fund and they steal it. This is a risk, but the level of supervision of this could be lowered by A LOT in many other cases where the emerging PM/AM does not have direct to the funds (managed account, AMC, etc. etc.).
b) Market risk: the fund manager is an idiot, and the market goes against the manager BADLY. It happens, sadly, but the solution is not to impose some strict rules on trading frequency/concentration/diversification/etc, etc: even Warren Buffet would complain about the diversification constraints?
So what? If the client is a ‘professional’ (and there is also a lot to talk about this…) just let them sign a contract with an explicit Stop Loss: once losses hit 30%, the manager must communicate and immediately liquidate all positions.
That’s it: No useless VAR/EV/Risk limits computation

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Status

Open

Board

eu/acc

Date

About 1 year ago

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