By: Philip Morgan

In a letter to the EU Commission published on 3 January 2022, ESMA has drawn attention to the fact that most EU regulators do not request or hold information on the extent of the offering of AIFs into the EU on a reverse solicitation basis (as opposed to through active marketing). 

Notable exceptions are Italy and Cyprus. CONSOB has reported that in Italy 25% of the total subscriptions in funds gathered by Italian asset managers directly were done on the basis of reverse solicitation.  It seems that this relatively high figure may have raised eyebrows, and sharpened ESMA’s focus on the issue.