AIFMD 2.0 – additional detail on liquidity management tools

The EU Commission has published near final “level 2” regulatory technical standards (“RTS”) on liquidity management tools (“LMTs”) required under AIFMD 2.0. The characteristics of each LMT have been framed in the RTS, however complying with the letter of the law may involve complexities that market participants were not expecting. There are also certain points of interpretation and application that are still unclear.

In our note we summarise the new rules, consider the new transitional period, and outline our thoughts on what EU AIFMs and UCITS should do next.