Alternative Investment Fund Managers Directive--the registered investment adviser's implementation checklist

The Alternative Investment Fund Managers Directive (the Directive or AIFMD) is now fast approaching its Jul 22, 2013 transposition date; the date for enactment across the European Union (EU) in each of its member states. Much of the work at the EU level that needed to be done to implement the Directive has indeed been done. The focus now begins to turn to the member state transposition efforts, which are rapidly being introduced. Indeed, individual member states are busily at work on legislation to transpose the Directive into local law. Member state regulators are likewise at work on their rule books. They are now in implementation mode. AIFMD is here and now is time to take stock of key checklist items for US investment advisers. It is time for US registered investment advisers to build a checklist to assess if the Directive will apply to them, and if so, how to adapt to its implementation.