The FCA has published further guidance about the information it will require from alternative investment fund managers in their Variation of Permission applications in January 2014. The key elements are reproduced below:
• Article 8(5) of the AIFMD does not require an applicant to provide information on their depositary arrangements for the application to be deemed complete.
• Firms can submit a VoP before the depositary arrangements for their AIFs are finalised, but firms should not leave Section 9 (depositary arrangements) blank.
• Where depositary arrangements have not been finalised, firms should complete Section 9 with the name of the intended depositary and details of when firms expect to be able to finalise their contractual arrangements.
• If a depositary has not yet been selected, firms should state that depositary arrangements are to follow.
• Firms should include a brief description of the due diligence that they have or will undertake on that depositary.
• Firms should ensure there will be enough time to conclude contractual terms with the chosen depositary before the anticipated date of authorisation.
• Firms should consider the need for depositaries to do their own due diligence as part of this process, and the likelihood that they may need to also engage with a large number of clients.
The full guidance note can be found at http://www.fca.org.uk/your-fca/documents/aifm-depositary-arrangements