The FCA has updated its website to provide more details of the process it will employ to review variation of permission applications submitted by UK alternative investment fund managers. Applications will be reviewed through a triage process to assess their completeness in order to be assigned to a case officer.
Despite HM Treasury making an announcement before Christmas that it planned to make changes to the AIFMD Regulations to allow for situations where managers have not received AIFMD authorization by 22 July 2014, the FCA is still encouraging managers to submit their applications as soon as possible. The industry awaits further clarification from the FCA and HMT but in the meantime advisors are also recommending managers continue to focus on submission of their VoPs.
The law firm Akin Gump has issued a very interesting bulletin on this change which is relevant to any managers seeking to comply with the AIFMD depositary-lite requirements in order to continue to market their funds to EU funds from the end of the transitional period, 22 July 2014. The bulletin which can be found by clicking here, confirms what we hear from many managers about their discussions with established depositary firms or administrators seeking to provide depositary-lite solutions – that is many are not yet ready to provide draft contractual terms and are unable to clearly articulate how depositary-lite will be implemented in practice. This continually surprises us and we encourage any managers frustrated in their efforts to date to agree terms and operating models with a depositary lite provider to contact us.
We offer a very pragmatic and transparent depositary-lite solution. We have balanced contractual terms and detailed due diligence materials which will enable you to make an informed decision. Selecting Indos does not involve any significant operational burden on your business (no trade file builds for example) – we simply work alongside your existing administrator and prime brokers and managers and their fund boards benefit from the independent oversight and reporting we provide.
To visit the FCA website click here and scroll down to “The Application Process”