ALFI_ESMA75-453128700-1012_Reply_form_MiCA_-_RTS_GLs_20240621.docx

Here are the key points summarized:

• ALFI suggests that the industry may be lacking background substantiated information on the topic, and recommends revising the guidelines at a later stage.
• ALFI supports ESMA's interpretation of the term "systems" in the mandate, considering both ICT systems and connectivity systems as part of the scope.
• ALFI advises adequate requirements for distant CASP and service providers to comply with due diligence requirements initiated from the depositary and AIFM.
• The TIBER-EU framework can be a relevant EU framework for this mandate, according to ALFI.
• Proportionality principle should apply in the guidelines, including minimal administrative arrangements while fostering operational flexibility.
• ALFI agrees with the inclusion of minimal administrative arrangements in Guideline 2, considering the proportionality principles and risk-based approach.
• ALFI does not have strong views on Guideline 5 on cryptographic key management.

Please note that these points are a direct summary of the document and do not include any additional information or context.