The appointment of a depositary is one of the most important strategic decisions that managers are tasked with under the AIFMD. Firms are required to have a depositary in place before they can have an authorization under the Directive. Further complicating matters is the fact that the few depositaries able to deliver these services may soon stop accepting new clients to mitigate the risks of having too large a client roster as they deal with the learning curve associated with the AIFMD.

• An explanation that this is one of the more complicated/contentious issues AIFMs are facing including some of the reasons.
• Issues in this area with member firm clients: a lack of consistent risk management processes, issues around oversight of operational functions, determining how best to demonstrate their control activities or data quality processes.
• How KPMG can help: Our teams can help you understand which tools and controls the depositary will need to have in place to help ensure an efficient and collaborative operating framework and supervisory model. Our team can also formally assess existing depositaries processes and make recommendations. 

AIFMD: Spotlight on depositaries (for more information)