Response to consultation Paper on Draft Implementing Technical Standards on reporting requirements for investment firms under Article 54(3) and on disclosures requirements under Article 49(2) of Regulation (EU) 2019/2033

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Question 1: Are the instructions and templates clear to the respondents?

Please see attached response

Question 2: Is the level of detail on small and non-interconnected investment firms templates and instructions sufficient and proportionate for the level of activity of these firms?

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Question 3: Are the instructions and templates IF 05.00 and IF 05.01 clear to the respondents?

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Question 4: Do the respondents identify any discrepancies between templates IF 06.01 - IF 06.13 and instructions and the calculation of the requirements set out in the underlying regulation?

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Question 5: Do the respondents identify any discrepancies between templates IF 07.00 – IF 08.00 and instructions and the calculation of the requirements set out in the underlying regulation?

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Question 6: Are the instructions and templates clear to the respondents?

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Question 7: Are the instructions and templates (IF 11.01, 11.02, 11.03) clear to the respondents?

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Question 8: Do the respondents identify any discrepancies between the template and instructions and the requirements set out in the underlying regulation?

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Question 9: Do the respondents identify any discrepancies between the template and instructions and the requirements set out in the underlying regulation?

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Question 10: Are the instructions and templates clear to the respondents?

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Question 11: Is the ITS text clear to the respondents?

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Question 12: Are the provisions of the RTS, the templates and instructions clear? In those cases where you identify issues, please provide concrete examples or detailed explanations to illustrate your doubt.

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Name of the organization

Alternative Investment Management Association