The FCA has updated its website to remind AIFMs seeking authorisation to take effect from 22 July 2014, they need to provide the FCA with the information requested in sections 8.4 a) to c) of the variation of permission form – by 20 June 2014 at the latest.
The required information is:
- a copy of the rules or instruments of incorporation of the AIFs managers intend to manage (for all AIFs, except Regulation 74 and 75 funds)
- fund 3.2.2R disclosures (for all AIFs, except Regulation 74 and 75 funds)
- confirmation that contractual arrangements are in place with all depositaries selected.
We also understand the FCA, as part of its review of variation of permission applications, is regularly requesting evidence of the due diligence managers have performed over their selected depositary providers. Managers may wish to use the INDOS Financial due diligence assessment checklist for this purpose. This can be downloaded here: AIFMD Depositary Due Diligence Assessment Checklist template