Gateway to the EU
WITHIN THE EUROPEAN UNION SINGLE MARKET gibraltarfinance.gi
AIFMD Overview
&
Marketing vs Reverse Solicitation
Joey Garcia Adrian Hogg James Lasry
Partner Partner Partner
ISOLAS Grant Thornton Hassans
Freedom of movement of:
1. Persons 2. Goods 3. Services 4. Capital
European Union
Single market with 28 countries
Gibraltar Finance
Centre in EU
EU Statistics
Inhabitants Global Wealth Global
• EU 500 million 7% $17.958 trillion 23.8% • US 320 million 4.5% $16.768 trillion 22.2% • China 1.357 billion 19% $9.240 trillion 12.2% • India 1.252 billion 17.5% $1.875 trillion 2.4%
Hong Kong Hedge Funds* *Hong Kong SFC
• AUM as of 30 Sep 2014 = US$120 billion
• 13 x increase from 2004 AUM = US$9.1 billion
• Investors:
EU = 17.7% = US$21.24 billion
AIFMD Overview
Alternative Investment Fund Managers Directive (“AIFMD”) imposes harmonised conditions and requirements on the structure and operation of AIFMs
in return authorised AIFMs will be able to market AIFs to professional investors across the EU
AIFM = Manager AIF = Fund
AIFMD – What’s new?
Conflicts of interest
Risk management
Liquidity management
Organisational requirements (Four-eyes/staff)
Annual audited reports
Reporting obligations to regulator
Requirement to have a depositary
AIFMD – What’s actually new?
Some NEW requirements imposed by AIFMD Capital requirements
Self-managed: €300,000 External managers: €125,000
Plus 0.02% on amounts exceeding €250 million AuM
Delegation requirements Gibraltar taking a flexible approach to “letter-box” provisions
Remuneration
40%-60% that deferred for 3 to 5 years and at least 50% in shares of the AIF concerned Gibraltar will adopt the FCA approach of proportionality to disapply these specific
provisions with respect to smaller managers
Local depositary Not relevant until July 2017 UCITS V – introduction of depositary passport?
Three Options
Reverse solicitation:
NOT MARKETING
“on its own initiative”
National Private Placement Regimes (“NPPRs”):
Marketing in a specific member state via respective member state NPPRs
“Small AIFMs”
“Non-EU AIFMs (Art. 42)”
Passporting:
EU wide marketing to professional investors in all 28 member states with the marketing passport
“In-Scope (EU and non-EU)”
GOLD STANDARD
Marketing vs Reverse Solicitation
Marketing
Article 4(1)(x) of AIFMD:
“’marketing’ means a direct or indirect offering or placement at the initiative of the AIFM or on behalf of the AIFM of units or shares of an AIF it manages to investors domiciled or with a registered office in the Union”
Reverse Solicitation
Recital 70 of AIFMD:
“This directive should not affect the current situation, whereby a professional investor established in the European Union may invest in AIFs on its own initiative, irrespective of where the AIFM and/or the AIF is established”
Marketing via NPPRs (without passport)
UK
Holland
Sweden
France
Germany
Marketing via
Notification
Notification
Approval
Approval
Approval
Commence-ment of
marketing
From notification
From notification
From approval
From approval
From approval
Depositary requirement
No
No
No
No
Yes
Undertake careful due diligence as marketing regimes are not fully harmonised
Passporting
“GOLD STANDARD”
EU wide marketing to professional investors in all 28 member states with the marketing passport
Access to market of 500 million people
Access to market of 23.8% of global wealth “In-Scope (EU and non-EU)”
Compliant, safest and most efficient
Penalties for Non-Compliance
• AIFMD does not set out specific penalties or sanctions for breach of the marketing restrictions.
• Left for individual Member States to determine what punishments are appropriate.
Regulatory Civil Criminal
• In the UK (for example) when an AIFM unlawfully markets an AIF such unlawful marketing qualifies as a criminal offence.
• Risk of private law actions from investors who may claim that the AIFM engaged in unlawful marketing or may rescind the contract.
EU Solutions
EU AIFM
Non-EU AIFM
Small AIFM
Gibraltar’s Fund Regime
Gibraltar Finance Centre: AIFMD, the Gibraltar option
Joey Garcia www.gibraltarlawyers.com
EU AIFMD Case Study and analysis: requirements and options
So……what are the main questions?
1. What is the effect of AIFMD on a Hong Kong based manager of a Fund today, and moving forward?
2. What are the options for access to professional investors in the EU both now, and in the future?
• Understand limits on reverse solicitation, marketing and private placement long term
• Build or Buy?
Non-EU routes to Europe How and when are you captured?
Hong Kong Manager
Marketing AIF in the EU
Private Placement (subject to additional AIFMD requirements
AIFMD – Marketing Passport
+ Private Placement
AIFMD – Marketing Passport
+ Private Placement??
Managing EU AIF
Delegation arrangements (subject to AIFMD requirements)
AIFMD – Management Passport + Delegation arrangements
AIFMD – Management Passport + Delegation arrangements
From 2013
From 2015
From 2018
AIFMD: Establishment, Key themes and business impact
• Externally managed: EUR 125.000 when more than 250 min AUM, 0.02% over this, capped on EUR 10 min
• Cash flow monitoring • Monitoring role and custody • Liability
• Markets and instruments • Illiquid assets, actual risk profile and • risk management tools • Results of stress tests • Leverage • Systemic risk information
• Objective reasons • No letterbox entity • Co-operation agreement • Monitoring role manager
• Functionally and hierarchically separate
• Due diligence investments • Limits on leverage • Stress tests
• Includes senior staff incl. senior management, portfolio manager and functions with an impact on risk profile
• Multi year framework, and variable elements, at least 40% deferred over 3 to 5 years
• Policy: adjustment needed to included further disclosure on Preferential treatment
• Extension of scope
• Guarantees for independent valuation
• Functionally independent from portfolio management
AIFMD: The Build option Hong Kong Manager – Sub or over 100m EUR Gibraltar or European AIF, Gibraltar AIFM
Gibraltar AIFM Hong Kong Delegated Manager
• Understanding key management functions
• Understanding the application procedure and requirements
• Core and Non-Core functions
• Understanding substance requirements
Gibraltar/EU Investment Fund
Delegation under AIFMD Understanding the operation and limitations of delegation
• Understanding delegation under AIFMD
• Objective reasons
• Letter box restrictions
• Effective supervision
Understanding objective reasons for delegation,
AIFMD: The Buy option Hong Kong Manager – Sub or over 100m EUR Gibraltar or European AIF, Gibraltar AIFM
Gibraltar AIFM Provider Hong Kong Delegated Manager
Result • Working solution • Pass-porting, selling to professional investors and long term planning option • (Subject to conditions, substance, qualifying criteria and limitation of amount
of tasks delegated)
Gibraltar/EU Investment Fund
AIFMD: Establishment, Key themes and business impact
• AIFM
• AIF requirement
• AIFM
• Portfolio management is delegated • Objective reasons • No letterbox entity • Co-operation agreement • Monitoring role manager
• AIFM • AFIM
• AIFM
• AIFM
Summaries Fund distribution across Europe, access to European Clients, and provision of cross borders services requires action.
• Understand action points and options
• Consider the alternative options. Plan for the long term
• Innovate and collaborate – We are here to help
Presentation 9 July 2015
Adrian Hogg
Partner
Grant Thornton Gibraltar
USER NOTE:
Before populating this
template with information,
you will need to save it
under a different name.
This ensures you don’t save over
your template while populating it. To
do this, under File choose ‘Save as’.
Rename your presentation to a
relevant title, and save it in the
correct location. You will then be able
to click the save shortcut while
creating the rest of the presentation,
which will save over your file.
USER NOTE:
To update the information
in this deck, just highlight
over the text you want to
update and re-type.
This will ensure type sizes and
locations will remain consistent
throughout at Grant Thornton
Proposals..
Non-EU AIFMs & Small AIFMs (below scope)
©2013 Grant Thornton International Ltd. All rights reserved
Non-EU AIFMs
Active
EU Marketing Passport
NPPRs (private placement) Passive
Reverse Solicitation
USER NOTE:
Typography
Bullet points are set to 20pt,
therefore short sentences are
advised.
Avoid ‘hanging words’ on a slide –
i.e. if one word rolls over to the
next line make sure you include a
second word. Use the return key.
USER NOTE:
Arrow assets
These arrows are not locked in
place, you should move them to
help balance the slide.
If there is no room for a graphic
asset, delete.
There are blank pages at the back
of this deck with assets for you to
copy and paste.
©2013 Grant Thornton International Ltd. All rights reserved
EU Marketing Options
USER NOTE:
People page
You will need to import people
from the Grant Thornton asset
library.
To change the photo, click inside
the grouped box to select the
picture box,right click and choose
“change picture’.
Because all the GT pictures are
cropped differently, you will have
to move the box to align with the
line.
You can use the arrow asset to
highlight the key contact.
Cropping people
Please refer to the PDF guide.
2013 - 2015
2015 - 2018
2018 onwards
• Private placement
• EU marketing passport • Private placement
• EU marketing passport • Private placement ??
©2013 Grant Thornton International Ltd. All rights reserved
EU Marketing Passport
USER NOTE:
Fast facts
The big number should be used to
draw the attention, and a short
explanation of the number aligned
next to the number.
The text alignment has been
created for you, but you can open
the small text box to make that
text wider/less deep.
These assets have been grouped
to make it easy for you to move
them around the page.
To amends the text content, just
click the text and scroll over and
re-type.
Use of a LIME number with the
arrows asset to sum up the slide.
Regulatory
Depositary Capital requirements Remuneration Risk management Liquidity management Valuation Reporting
Member State of Reference
Will be determined by: • where most AIFs
established • where AIFM intends to
develop most effective marketing
Member States jointly decide
Total Expense Ratio (TER) Depositary Policies Procedures Valuation (external valuer) Reporting
22 July 2015
By 22 July 2015 ESMA is required to
report to the European
Commission on the extension of the EU marketing passport to non-EU AIFMs.
Loss of Control
Increased Cost
Increased Regulation
©2013 Grant Thornton International Ltd. All rights reserved
USER NOTE:
Blank page
This is left blank so you can fill it
with your own content.
EU Marketing Passport
Non-EU AIFM
EU AIFM
CONTROL:
• Regulation • Cost • Member state of reference
• Regulation (whole structure) • Cost (total expense ratio) • Member state of reference
(loss of control)
©2013 Grant Thornton International Ltd. All rights reserved
USER NOTE:
Blank page
This is left blank so you can fill it
with your own content.
Marketing via NPPRs (private placement)
Marketing via Article 42
Three principal requirements
a) Comply with Articles 22, 23, 24 and 26 to 30
b) Appropriate co-operation agreements in place between EU and non-EU competent authorities
c) Non-EU AIFM and non-EU AIF (as applicable) is not a non-cooperative country
Articles 22, 23 and 24
• Annual reporting • Disclosure to investors (transparency) • Reporting obligations (to competent
authorities)
Articles 26 to 30
• Obligations for AIFMs that acquire non-listed companies
©2013 Grant Thornton International Ltd. All rights reserved
USER NOTE:
Blank page
This is left blank so you can fill it
with your own content.
Marketing via NPPRs (private placement)
Undertake careful due diligence as marketing regimes are not fully harmonised
Member States may impose stricter rules on the non-EU AIFM in respect of marketing in their territory
Potential regulatory, civil and/or criminal liability for marketing rule breach
Extensive due diligence required
UK
Germany
Marketing via
Notification
Approval
Commence-ment of
marketing
From notification
From approval
Depositary requirement
No
Yes
©2013 Grant Thornton International Ltd. All rights reserved
USER NOTE:
Blank page
This is left blank so you can fill it
with your own content.
Marketing via NPPRs (private placement)
May 2015 (www.ft.com)
“550 private equity and hedge
fund managers from outside the
EU have registered to market
their funds in the UK”
263 are from the US;
14 from Hong Kong and Singapore
©2013 Grant Thornton International Ltd. All rights reserved
USER NOTE:
Blank page
This is left blank so you can fill it
with your own content.
Small AIFM (below scope)
AIFMs who manage AIFS of less than €100 million
AIFMs who manage unleveraged closed-ended AIFs (no redemption rights within 5 years) of less than €500 million
Open-ended
Closed-ended
If exempt only
Articles 3(3), 3(4)
and 46 apply
Article 3
©2013 Grant Thornton International Ltd. All rights reserved
USER NOTE:
Blank page
This is left blank so you can fill it
with your own content.
Small AIFM (below scope)
Light Regulation
Regulatory
Article 3(3), 3(4) and 46
Marketing
Via NPPRs (private placement)
Cost
Limited regulatory impact
Ability to Market
Low Cost
©2013 Grant Thornton International Ltd. All rights reserved
USER NOTE:
Blank page
This is left blank so you can fill it
with your own content.
Small AIFM (below scope)
FUND TYPE
EU
Non-EU
Cayman Islands Fund
Hong Kong Fund
BVI Fund
Irish Fund
Gibraltar Fund
Luxembourg Fund
©2013 Grant Thornton International Ltd. All rights reserved
USER NOTE:
Blank page
This is left blank so you can fill it
with your own content.
Small AIFM (below scope)
Gibraltar Fund
• EU compliant
• OECD compliant
• Can opt-in to AIFMD
• Some NPPR advantages (Germany)
• Segregate EU regulation within an EU fund
EU Special Features
©2013 Grant Thornton International Ltd. All rights reserved
USER NOTE:
Blank page
This is left blank so you can fill it
with your own content.
Small AIFM (below scope)
Gibraltar Fund
• Private equity • Real estate
Parallel Fund
Feeder Fund
• Feed to master fund • Feeder and master (below scope)
Segregate EU regulation within
an EU fund
GIBRALTAR’S FUNDS REGIME
James Lasry Partner & Head of Funds
Gibraltar fund structures
Open / closed ended investment companies
Protected Cell Companies (PCCs) (statutory segregation of cells)
Limited partnerships
Unit trusts
Protected Cell Companies
Liabilities attributable to each cell of the PCC will be statutorily segregated from those of other cells.
Cells may have different investment strategies and fee structures.
No limit to the number of cells.
The PCC is the legal entity. Cells do not have separate legal personality.
Cells can be open-ended, closed-ended or a mixture of both.
Your Fund PCC Limited
Cell A European Equities
Cell B Global Fixed Income
Gibraltar fund regimes
Private Funds
Experienced Investor Funds (EIFs)
Super EIFs - AIFMD compliant
Non-UCITS Retail Funds
UCITS Funds
Private Funds
A private fund is not licensed, authorised or regulated by the Financial Services Commission. FSC must be notified on launch and annually.
Private funds can only be promoted to an identifiable category of persons whose number is
less than 50: Family, friends and close clients Family offices Managers seeking to establish track record
Investors must have sufficient information to make an informed investment decision, i.e. PPM.
No minimum investment.
Private funds can not be structured as protected cell companies.
A private fund can be converted into an EIF after one year.
The Experienced Investor Fund Regime
DEFINITION OF EXPERIENCED INVESTORS: An “experienced investor” is defined as: An investment professional; An individual with a net worth (together with spouse) exceeding €1 million excluding residence;
A participant who invests €100,000;
A participant who invests €50,000 and is professionally advised;
A professional client as defined under MiFID.
EIF requirements
ELEMENTS OF AN EIF 2 Gibraltar resident directors authorised by the FSC
Gibraltar based Administrator or authorised foreign administrator
Annual audit by a Gibraltar registered auditor
Offer document complying with the Financial Services (Experienced Investor Funds) Regulations 2012
Custodian need not be in Gibraltar
Can be self-managed
Investment Manager can be domiciled anywhere in the world as long as it is authorised to provide investment
management services in its home jurisdiction
EIF Launch Pre-authorisation launch – submit documents to FSC within 10 business days of launch Pre-launch authorisation – submit documents 10 business days before launch
Advantages of an EIF in Gibraltar
Quickest time to market in EU
Only EU jurisdiction to have pre-authorisation launch option
Competitive costing
No statutory investment or borrowing restrictions
Fully tax neutral Access to EU Parent Subsidiary Directive Can elect to check the box for US tax purposes No withholding tax
Common law jurisdiction (English – mother tongue)
Appeals to UK Privy Council (same as Cayman Islands and formerly Hong Kong)
Listing possible (Gibraltar Stock Exchange or other) / Bloomberg pricing
Redomiciliation facilitated
LIGHT TOUCH not SOFT TOUCH
JURISDICTIONAL COMPARISON
Gibraltar - the European Cayman
Gibraltar Cayman Islands Luxembourg
Legal system English-based common law English-based common law Civil law
Investment restrictions
None None Specialised Investment Funds (SIFs) must comply with risk-spreading requirements
Tax Tax neutral Tax neutral Annual subscription tax (taxe d’abonnement) levied on funds
Fund registration EIF may commence trading as soon as it launches. Notification to regulator within 10 days of launch
Fund registered by submission of relevant documents to regulator
Fund needs to wait until formal approval has been received from the regulator CSSF before launching, usually 12 to 18 weeks
Local depositary? No requirement No requirement Yes
EU Passport? Yes No Yes
EIFs & AIFMD
BELOW SCOPE AIFMD The simple EIF is the basic alternative fund regime in Gibraltar
Can opt in to AIFMD regime in order to obtain passport even if below €100 million
IN-SCOPE AIFMD Simple EIF (opt-in or in-scope) + AIFMD Regime = Super EIFs
EIF Regime works TOGETHER with
the AIFMD Regime
Timeline – AIFM setting up new AIF
Gibraltar
Other EU jurisdictions
Week 1 Week 2 Week 3 Week 4 Week 5 Week 6 ~~~ Week 18 Week 19 Week 20 Week 21
~~~
On or before day 20:
• AIFM receives
FSC notification
• AIFM can market
EIF under EU
passport
After 6 to 18 weeks:
•AIF approved and
registered
•AIFM submits AIFMD
notification file
(On or before 20
days later):
•AIFM receives
regulator notification
•AIFM can market
AIF under EU
passport
On day 1:
•EIF launch
•Submit EIF
notification form
•AIFM submits
notification file
On day 1:
•Submission of
AIF registration
documents
20 days
6 to 18 weeks + 20 days ~~~
Conclusion
Why EU is important to raising AuM
How EU regulates the marketing of funds
Dangers of reverse solicitation Difficulties of private placement Passporting
AIFMD compliant vehicles (EU AIFM)
Build or buy
Aspects of non-EU AIFMs Not as easy as it seems
Aspects of Small AIFMs
Options available
THEREFORE, if EU then Gibraltar Closest to what investment community is used to (Cayman) The safe way to market in the EU
MAKE GIBRALTAR YOUR GATEWAY TO EUROPEAN UNION INVESTORS
GSX Visibility and Connectivity
1
2015
2
GSX – A Passive Route to Europe
Open-ended Funds (Listing now) Time & Cost To Market Visibility Connectivity – audit trail
Closed-ended Funds (Listing 2H 15)
Asset Backed Securities (Listing late 15) Exchange Traded Instruments Not AIFs Making a non-UCITS open-ended fund UCITS eligible
Gibraltar’s First Exchange
3
Introduction To GSX GSX is a Gibraltar-based private company, an EU Regulated Exchange
licensed by the Financial Services Commission. Commenced its operations on 10 November 2014 as a technical listing exchange for open-ended funds.
Will extend its listing services in 2015 to include: • Closed-ended funds, • Asset-backed securities, • Insurance linked securities, • Debt securities • Derivative securities
Provides a robust listing process that is fast to market and commercially
attractive compared to its European peers. This may be a particularly important consideration for small and medium sized funds
An Alternative for Alternatives
4
The Global Drive To Fund Listing
Listing Balances The Needs Of Investors And Fund Managers
Investors Demand
Managers Require
Marketability
Accessibility
Visibility
Reporting
Transparency
Disclosure
5
Listing My Fund On GSX?
Unique EU Offering
3 Core Messages:
Time & Cost To Market. Listing is now accessible to small to medium sized managers
Visibility. GSX listing raises profile through EU Fund Distribution network via newsletter
Connectivity. Unique connection mechanism provides audited trail of investor enquiry
6
Time and Cost to Market
Why and How is GSX Faster to Market than other EU
Exchanges?
Philosophy of Disclosure, not prescribed rules as to what a Fund may or may not do
Practical: Less modifications to existing documentation
Speed of the Listing Authority
A Practical, Robust Code Not Reliant On Prescribed Rules
7
A 6 to 8 Week Listing Process
MEMBER FIRM
GSX MLC
LISTING
OPEN ENDED FUND
LISTING AUTHORITY
GSX
Appoint a Listing Member Firm. Responsible for preparation of
application bringing listing to market. Less than 4 weeks Member Firm submits all documents to GSX who review pack within
5 days of receipt. May seek further clarification. Once satisfied, GSX will forward the completed application to the GSX MLC
The GSX Membership and Listing Committee (MLC) shall review all
applications usually within 2 days of receipt after which it will make its recommendation for approval to the Listing Authority (Independent Body manned by FSC);
MLC submit application to the Listing Authority . The Listing Authority
has 10 days in which to either approve the application or ask further questions. Answers provided, the Listing Authority has a further 10 days in which to either approve or decline
Time and Cost to Market GSX 4 Stage Listing Process
8
Visibility & Connectivity
GSX Will Help Funds To Raise Visibility in EU. How?
North America Funds
Latin America Funds
Asia Funds
? ?
?
9
Visibility
GSX building a Market Place via GSX Newsletter
FUND OF FUNDS
PRIVATE BANKS
IFAs
LIFE INSURANCE COMPANIES
FAMILY OFFICES
INVESTMENT BANKS
HEDGE FUND DATABASES
CONSULTANTS HIGH PRIORITY
PHASE 2
DISTRIBUTION HUBS
10
Connectivity GSX CONNECT
A Connectivity Process Unique to GSX
SOURCE
CONNECT
LIST
PROTECT
Transparency, Visibility, Recognition, Speed to Market,
Economic Investors can search for Asset Class, Currency, Geography,
Manager Investors must Login & Register, sign Disclaimer, data stored
and audit trail established Connecting Investors with Managers directly via email.
Managers responsible for subsequent DD
11
GSX CONNECT
GSX Website Specifically For The Fund Industry
12
Fund Discovery Process
Managers Can LIST Clear Fund Details
Users Access Greater Fund Details, NAV and Performance
13
Connecting Your Fund
Users Can CONNECT Directly With Managers
Users Once Registered Can Contact Managers Directly Managers Must Conduct Their Own DD
14
Audit Trail
Audit Trail & Disclaimer Process
Users Must Agree To Disclaimer, T&C
15
Who Can List on GSX?
Applicants Must Be:
Open-ended Funds Approved Jurisdictions Directors & Investment Manager Experience
Applicants Can Be:
Start-up Funds Established Funds
Especially Attractive For Small To Medium Sized Funds
16
Closed Ended Funds (late Q3 2015)
Unique Offering on an EU Exchange
Approved Prospectus EU Regulated exchange demands Prospectus Directive
compliant listing particulars for transferrable securities Philosophy of Disclosure, not prescribed rules as to
what a Fund may or may not do above EU regulations Practical: Less modifications to existing documentation Speed of the Listing Authority
Speed to market and cost savings
17
Closed Ended Funds
An Alternative for Alternatives
Visibility EU Fund Distribution network
Liquidity Co-listing on MTF for liquidity and price transparency
18
Securitisation (late Q3 2015)
Asset Backed Securities or EXCHANGE TRADED INSTRUMENTS (ETIs) A stock exchange traded security that is backed by
an underlying asset or basket of assets and delivers the delta one performance of the underlying
19
Securitisation CASE STUDY
Cash
Cash
ETI Units
SECURITIZATION COMPANY
HEDGE FUND
ASSET MANAGER
EU PROFESSIONAL INVESTOR
MANAGEMENT COMPANY
Fund Units
Structure Allows For A Number Of Promotion Options
SELF PROMOTE
EU LICENSED
PROMOTER
20
ETIs – Features & Benefits
Repackage a Collective Investment Scheme into an EU Transferrable Security
Regulation: ETI’s issued By Securitization SPV fall under ECB Regs
ETIs are not AIFs Flexible Choice of Asset Class (HF, VC, PE etc)
ETIs have no restriction on asset class securitized ETI’s Are “Pass Through” Instruments with 1:1 participation
ETIs feeders into underlying assets. No leverage Passporting & Promotion Rights Throughout EU
ETI securities listed on GSX (ESMA approved EU exchange) issued with approved prospectus automatically eligible asset for UCITS funds.
Joanne Beiso
Gibraltar Financial Services Commission
Gibraltar Financial Services Commission
EU regulator
• Compliant with EU directives
Matching UK standards
Satisfactory IMF, FATF and statutory reviews
Marketing
Passporting
National Private Placement Regime
Reverse solicitation
Unsolicited?
Undertake careful due diligence as marketing regimes are not fully harmonised
Passporting Notification forms providing key details:
Programme of operations
Incorporation documents
Identity of depositary
Information provided to investors
20 days from establishment to passport
As long as FSC is satisfied
EIF - 20 days to market in EU
Day 1
• AIF notified as EIF and passporting documents submitted
Day 10 • EIF registration decision made
Day 20 • AIFM advised by FSC it can passport
NPPR Notification or Application
different approaches
Requirements change by EU country
Limitations on how can market
Cannot advertise
2018...
Top Related