Abstract
ABSTRACTThis article draws on empirical evidence suggesting a shift of credit provision from banks to the alternative investment fund sector to argue that current deficiencies in fund regulation have not prevented such a shift, if not actually encouraged it. The evidence is drawn from the new Pan-European Private Placement Market, and first- and second-order analyses are undertaken to show a shift of credit risk (intermediation) into the hands of US funds in particular, and a concentration of risk amongst herds of smaller funds which have the potential to act as one. The data highlight defects in the scope of the macroprudential oversight mechanisms deriving from the Alternative Investment Fund Management Directive (AIFMD). These findings form the basis for proposals to remedy AIFMD as part of the move to a Capital Markets Union.
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