AIMA

The Alternative Investment Management Association

Alternative Investment Management Association Representing the global hedge fund industry

The EU AIFMD: What does it mean for managers of Cayman and BVI Funds?

By Paul Govier, Partner

Maples and Calder

Q3 2013

 

The European Union (EU) Directive on Alternative Investment Fund Managers (AIFMD or "Directive") was due to come into force across the EU on 22 July 2013, although several member states are yet to formally implement it.  Initial drafts of the Directive indicated that one objective of the Directive was to bring 'onshore' the investment funds established in successful 'offshore' locations such as the Cayman Islands and British Virgin Islands (BVI). However, it appears that the outcome of the Directive has actually seen a trend towards fund managers establishing both offshore funds in the Cayman Islands or the BVI and EU based fund products in EU member states - such as Ireland - in order to have a complimentary suite of products which can appeal to investors based in different global markets.

 

This article seeks to summarise how the Directive will regulate the marketing of funds established in the Cayman Islands and the BVI across the EU under the Directive, both now and in the future.

 

Summary of marketing regime under the Directive

 

The Directive regulates marketing to EU investors based on:

 

(a)    where the alternative investment fund manager (AIFM or "Manager") is based;

 

(b)    where the alternative investment fund (AIF or "Fund") is established; and

 

(c)    when the marketing is to take place.

 

 

Phase 1: Transitional period

 

Each EU member state was supposed to implement the Directive by 22 July 2013; however, about two-thirds of member states have not yet done so.  Once implemented, the Directive contains certain transitional provisions that are subject to interpretation by local EU regulators.  Therefore, the marketing rules that apply between now and the expiry of the relevant transitional period will be determined on a member state by member state basis.  In certain jurisdictions and on certain conditions, Cayman Islands and BVI funds can continue to be marketed until the expiry of the relevant transitional period without having to comply with the Directive.  As this varies by member state, Managers of Cayman Islands and BVI funds should take specific advice from local legal counsel on whether they can benefit from this transitional relief.

 

Phase 2:  The end of any transitional relief to 2015

 

The regime governing marketing to EU investors is determined by where the Manager and the Fund are based. If a Manager is established (i.e. has its registered office) in the EU and is managing a Fund established (i.e. authorised or with a registered office) in the EU, it will be able to apply for a passport to market its EU Fund to 'professional investors' across the EU. If the Manager is not established in the EU or the Fund is not established in the EU, then the Manager will not be able to obtain a passport to market the Fund across the EU.  Instead, it will have to rely on marketing the Fund in EU member states subject to each member state's local requirements - otherwise known as the national private placement regimes (NPPRs) - or simply accept investors on a 'passive placement' or 'reverse solicitation' basis.


Phase 3: 2015 to 2018

 

By July 2015, the European Securities and Markets Authority (ESMA) will recommend whether or not the passport regime should be extended to countries outside the EU ("Third Countries") (including the Cayman Islands and BVI). The EU Commission, with the consent of the EU Parliament and the EU Council, will then decide whether or not to follow that recommendation.

 

If it is agreed that the passport regime should be extended to include Third Countries, there will then be a period of a further three years (i.e. until 2018) where Third Country Funds and Third Country Managers may choose whether or not to apply for the passport or to continue to use a private placement regime. After such a decision is made, private placement will fall away and Third Country Funds and Third Country Managers will only be able to market in the EU with a passport. If ESMA, the EU Commission, the EU Council or the EU Parliament decide that the passport regime should not be extended to Third Countries then the private placement regime will continue indefinitely.

 

Phase 4: 2018 and beyond

 

If the passport regime is made available to Third Countries, then Managers and Funds from outside the EU will only be able to market to EU investors with such passport (and will have to comply with the Directive). If the passport regime is not extended, then the NPPRs will continue indefinitely.

 

Marketing under NPPRs

 

Currently, marketing to EU investors is governed by each individual member state's national law. The ability to market using the NPPRs will continue until at least 2018 (see above) provided that two minimum requirements of the Directive are satisfied:

 

(1)     Appropriate co-operation arrangements are in place between the relevant EU member state and Third Country regulator(s); and

 

(2)     The Third Country is not listed as a Non-Cooperative Country and Territory (NCCT) by the Financial Action Task Force (FATF).  Neither the Cayman Islands nor the BVI are listed.

 

Exactly who the co-operation agreements must be between depends on the location of the Fund, the Manager and the country in which the Fund is to be distributed.

 

(a)     In the case of an EU Manager of a Third Country Fund (e.g. a London Manager of a Cayman Fund), the co-operation agreement must be in place between the Manager's regulator (e.g. the UK's Financial Conduct Authority (FCA)) and the Fund's regulator (e.g. the Cayman Islands Monetary Authority (CIMA)).

 

(b)     In the case of a Third Country Manager of an EU Fund (e.g. a US Manager of an Irish Fund), the co-operation agreement must be between the Manager's regulator (e.g. the Securities and Exchange Commission (SEC)) and the Fund's regulator (e.g. the Central Bank of Ireland).

 

(c)      In the case of a Third Country Manager of a Third Country Fund, the co-operation arrangements will need to be between the Manager's regulator (e.g. the SEC), the Fund's regulator (e.g. CIMA) and regulators in each of the EU member states in which the Fund will be marketed (e.g. the FCA).  Current arrangements are sufficient but there is a further two years for that to be determined or addressed.

 

Although this sounds involved, in practice we expect that these arrangements will not be problematic for Funds established in the Cayman Islands or BVI.  Both jurisdictions have already agreed the form of co-operation arrangement with ESMA (on behalf of the EU regulators).  The model agreement is now in the process of being executed by regulators in each of the relevant member states and Third Countries, including the Cayman Islands and BVI.  At the time of writing, CIMA and the BVI Financial Services Commission (FSC) have each completed the execution of co-operation agreements with 25 of the 30 relevant European regulators:

 

The Netherlands

Estonia

France

Poland

Belgium

United Kingdom

Ireland

Bulgaria

Portugal

Greece

Romania

Malta

Luxembourg

Slovak Republic

Cyprus

Hungary

Czech Republic

Iceland

Sweden

Norway

Finland

Liechtenstein

Denmark

Lithuania

Latvia

 

 

Other EU member states still to sign agreements with the Cayman Islands and BVI at the time of writing are Austria, Germany, Italy, Slovenia and Spain. It is understood that both the Cayman Islands and BVI regulators have offered to enter into, and are actively trying to conclude, a cooperation agreement with each of these member states’ regulators.

 

For a Third Country Manager to use the NPPRs, it will also need to comply with the 'transparency' and 'asset stripping' requirements of the Directive. However, Third Country Managers will not have to comply with any other aspects of the Directive, including remuneration restrictions, leverage restrictions or depository requirements.

 

The 'transparency' requirements effectively comprise reporting and disclosure obligations. In summary:

 

Annual report & audited financials

(a)      An annual report and financial statements must be published for each EU AIF managed/each AIF marketed in the EU, within six months of year-end. This requirement is ex post facto and only applies from 22 July 2013 onwards for the next set of financials.

(b)     Accounting information must be audited by a qualified auditor meeting international auditing standards in force in AIF’s domicile. Auditor’s report (and any qualifications) must be reproduced in annual report.

(c)      The report must be made available to EU investors on request, and (for EU AIFs) to regulator of AIF’s home member state.

(d)     Most mandatory disclosures would be industry standard and uncontroversial.

(e)     Most noteworthy requirement concerns disclosure of AIFM’s remuneration are as follows:

(i)       Total remuneration for the financial year, split into fixed and variable remuneration, paid by the AIFM to its staff, and number of beneficiaries, and, where relevant, carried interest paid by the AIF; and

(ii)     The aggregate amount of remuneration, broken down by senior management and members of staff of the AIFM whose actions have a material impact on the risk profile of the AIF.

Pre-investment disclosure to investors

(a)      Certain mandatory disclosures must be provided to prospective investors: (i) in advance of investment; and (ii) upon any material change to such information, for each EU AIF managed/each AIF marketed in the EU.

(b)      Most mandatory disclosures would be industry standard and included in most well-drafted offering documents.

(c)      Any additional disclosures could be best dealt with in an AIFMD-specific supplement to offering document/ marketing materials.

(d)     One of the more noteworthy requirements is for disclosure of preferential treatment (e.g. side letters). Description of treatment, type of investors who benefit and any legal/economic links they may have to AIF/AIFM should be provided, but no disclosure of specific terms is needed.

(e)     Changes to the prospectus could result in a knock-on impact for other AIF documentation and you will need to factor in any investor and regulatory approval timeframes.

(f)      These changes must be made and be effective on or before 22 July 2013.

Periodic disclosure to investors

(a)      Periodic disclosure to investors must, for each EU AIF managed/each AIF marketed in the EU, include details of:

(i)       any illiquid assets which are subject to special arrangements (i.e. side pockets);

(ii)     any change to the AIF’s liquidity position (e.g. activation of gates, redemption suspension),

(iii)   AIF’s risk profile; and

(iv)   for leveraged AIFs, the total leverage and any changes to the maximum leverage/rehypothecation rights.

(b)    Disclosure must be provided as often as required by AIF’s rules and at a minimum at same time as annual report.

Reporting to regulators

(a)      Disclosure must be made to the regulator in each member state where the AIF is being sold (and the member state of Reference from 2015), about the principal markets and investments in which the AIFM trades, and the relevant AIF’s portfolio diversification including principal exposures/ concentrations;

(b)      For each EU AIF managed/each AIF marketed in the EU, disclosure must  be made to the regulator in each member state where the AIF is being sold (and the member state of Reference from 2015), details such as liquidity, risk profile, main categories of assets traded, turnover, performance, and (where relevant) leverage;

(c)      Regularity of required reporting determined by AUM:
(i) semi-annual
where AUM <€1bn;
(ii) quarterly where AUM>€1bn;
(iii) quarterly in respect of any single AIF which AUM>€500m; and
(iv) annual for unleveraged
private equity AIFs.

(d)     Reporting to regulators is due to commence by and from 22 July 2013.

 

 

The 'asset stripping' provisions involve additional notification and disclosure requirements, together with provisions preventing certain conduct in relation to Managers which engage in the takeover of unlisted EU companies. They will generally only be relevant to managers of private equity funds.

 

EU Managers will have to comply with the Directive, irrespective of where their Fund is established. However, if they choose to privately place a Fund established in a Third Country, they will not have to appoint a 'Depositary'; rather, they will be required only to ensure that one or more persons performs the cash management, custody and oversight functions set out in Article 21(7), (8) and (9) of the Directive.  Therefore, they should be able to continue to market their Funds to the same category of investors as present without having to introduce a Depositary to the fund structure.  Of course, if they want the benefit of the passport, they would need to establish an EU AIFMD compliant fund structure in a member state, such as Ireland, and appoint a Depositary.  Managers will need to weigh up the benefits of the improved market access afforded by the passport against the cost of introducing a Depositary.

 

Marketing under a passport

 

From 2013 to 2015, only EU Managers of EU Funds will be able to apply for a passport. If the decision to extend the passport to Third Countries is taken in 2015, EU Managers of non-EU Funds will be able to obtain a passport to market those non-EU Funds throughout the EU, provided the Third Country in which the Fund is established satisfies the following 'three test' conditions:

 

(a)       Appropriate co-operation arrangements are in place between the Third Country in which the Fund is established and the member state (or member state of reference) of the Manager;

 

(b)       The Third Country is not listed as an NCCT by the FATF; and

 

(c)        A tax information exchange agreement (TIEAs) - in accordance with OECD requirements - is in place between the relevant Third Country and the jurisdiction in which the non-EU Fund will be marketed.

           

A Manager established in a Third Country will also have to 'opt in' to comply with the Directive.  To do so, it will have to effectively 'adopt' an EU home, called a 'member state of reference'. This will entail the Manager applying to a particular EU regulator for authorisation; submitting to that EU regulator's supervision in respect of its compliance with the terms of the Directive; and appointing a legal representative in the relevant EU member state to act as a point of contact with that EU regulator. In addition, its own jurisdiction and, if established outside the EU, the Fund jurisdiction must also satisfy the conditions described above.

 

Applying these tests to the Cayman Islands and BVI:

 

(a)          CIMA and the BVI FSC have agreed the form of co-operation arrangements with ESMA and completed signing with 25 of the 30 relevant member state regulators (as above).  It is expected that this process will be completed by 2015.

 

(b)          Neither the Cayman Islands nor the BVI are blacklisted by the FATF.

 

(c)          The Cayman Islands and BVI are on the OECD White List and, to date, each has approximately 30 TIEAs with countries including (relevantly) the Czech Republic, Denmark, Finland, France, Germany, Iceland, Ireland, Italy, Netherlands, Norway, Portugal, Sweden and the United Kingdom.

 

It is therefore likely that if the passport regime is to be extended to Third Countries, the Cayman Islands and BVI will be eligible jurisdictions to access it.  However, it is best to await further guidance from ESMA on the issue over the next two years.

 

Exemptions

 

There are certain circumstances in which the Directive will not apply at all. These include:

 

(a)      Hedge funds with AUM €100 million or less; private equity funds of AUM €500 million or less;

 

(b)      Certain qualifying securitisation special purpose companies;

 

(c)      Single investor funds (e.g. 'funds of one' and managed accounts); and

 

(d)      Funds that are only sold in the EU on a passive placement or reverse solicitation basis.

 

The latter two exemptions are particularly important for Managers located outside the EU since it means that they can accept subscriptions from EU investors if they do not initiate the offering or placement (passive placement). It also means that managed accounts can be run for single EU investors outside of the scope of the Directive.  In both cases, however, there are some detailed technical requirements that need to be carefully considered before relying on the safe harbour, particularly if intending to rely on passive placement or reverse solicitation.  Advice from qualified local counsel in the relevant jurisdictions is required to rely on these exemptions.

 

Transitional Scenarios

 

I am a US Manager of a Cayman Fund - what does this mean for my ability to access EU investors?

 

Transitional period

 

You may be able to continue to market your funds under existing local member state national private placement rules but this is an entirely jurisdiction-specific analysis.  Take advice.

 

Transitional period to 2015

 

Subject to checking that the necessary co-operation agreements have been signed, you will be able to continue to privately place your Cayman Islands or BVI fund in the EU by complying with the 'transparency' and 'asset stripping' provisions of the Directive and the relevant NPPR (if any). Otherwise, the Directive will not apply to you; but, equally, you will not be able to obtain a passport for cross border marketing within the EU.

 

From 2015 to 2018:

 

You may be able to obtain a passport for cross border marketing in the EU. That will require a decision to that effect by ESMA, the EU Commission, the EU Parliament and the EU Council in about 2015, two years after implementation.

 

If so, to get the passport you will have to comply with the Directive in full; you will have to apply for authorisation/supervision by an 'adopted' EU regulator and the US and the Cayman Islands will have to both pass the 'three tests' previously mentioned.

 

If you do not get a passport, you will continue to be able to use the private placement regime until at least 2018.

 

From 2018 and beyond:

 

(a)      If the passport is introduced for Third Countries, you will be required to obtain one to continue to market in the EU. It is expected that your Cayman Islands and BVI Funds will be eligible for a passport, if it is made available.

 

(b)   If the passport is not made available to Third Countries in 2015, private placement will continue to be available indefinitely.

 

Always:

 

You will always be able to:

 

(a)    retain existing EU investors in your existing funds;

 

(b)    reverse solicit or passively place your fund in the EU; and

 

(c)    run managed accounts for single EU investors.

 

In short?

 

The most likely outcome for a US Manager with a Cayman Islands Fund is broadly the status quo: the ability to privately place, subject to local law, until at least 2018 but with additional reporting and disclosure obligations (and if relevant, asset stripping restrictions); the ability to reverse solicit EU investors; and the ability to run managed accounts for single EU investors.  But if you want to maximise your EU distribution capability and obtain a passport, then establishing a parallel EU AIFMD compliant structure in for example, Ireland, to target EU investors is the way forward.

 

I am a UK Manager of a Cayman Fund - what does this mean for my ability to access EU investors?

 

Transitional Period:

 

You may be able to continue to market your funds under existing local member state national private placement rules but this is an entirely jurisdiction specific analysis.  Take advice.

 

From 2013 to 2015:

 

You will be able to continue to privately place your Cayman Islands Fund in the EU, subject to confirming the necessary cooperation agreements are signed.  You will have to comply with the Directive other than appointing a Depositary, provided you satisfy the 'depositary lite' requirements previously described.

 

From 2015 to 2018:

 

a. You may be able to get a passport to market your Cayman Islands or BVI Fund. That will require a decision to that effect by ESMA, the EU Commission, the EU Parliament and the EU Council two years after implementation. The Cayman Islands and BVI fully expect to meet the 'three tests'.

 

b. If you do not obtain a passport, you will be able to continue to use the private placement regime until at least 2018.

 

From 2018 and beyond:

a. If the passport is introduced for Third Countries, you will be required to obtain one to continue to market your Cayman Islands Fund in the EU. If the passport is not expanded to Third Countries in 2015, the NPPRs will remain available indefinitely.
 

Always:

 

You will always be able to:

 

(a)    retain existing EU investors in your funds;

 

(b)    reverse solicit or passively place your fund in the EU; and

 

(c)    run managed accounts for single EU investors.

 

In short?

 

(a)           For existing Funds:  the status quo: i.e. (subject to checking the relevant co-operation  agreement has been signed) the ability to market to EU investors subject to NPPRs until at least 2018; the ability to reverse solicit EU investors; and the ability to run managed accounts for single EU investors. Unless the Fund's target investor base is particularly Eurocentric, it is unlikely to be desirable to redomicile the existing Fund. If the target investor base is Eurocentric, an additional parallel European Fund (Irish Funds being particularly popular), or feeder fund, is likely to be as easy to establish and will compliment your existing BVI or Cayman Islands Funds and will maximise global distribution opportunities.

 

(b)           For new Funds: a careful consideration of distribution strategy and target investor base.  For many investors, an EU AIFMD compliant fund structure, for example in Ireland, will become necessary or desirable.  For others, Cayman Islands or BVI Funds may be preferred.  Managers will need to ensure they select their fund domicile by targeting it at the relevant investor; there is no one size fits all solution.

 

 

paul.govier@maplesandcalder.com  

www.maplesandcalder.com

 

 

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